Overview of EHS Policy, Team & Programs

GE’s EHS policy contains clear and simple aspirational goals for all our operations around the world:

• Expect 100% EHS compliance everywhere GE operates or sells products
• Eliminate hazards and provide a safe working place
• Minimize the use and release of hazardous materials
• Assess all new activities and products for EHS impacts
• Implement the GE EHS management system in all locations

To make these aspirational goals a reality, the EHS management system focuses on four key building blocks:

1. Operational responsibility and accountability for EHS performance
2. EHS programs applicable to GE’s global operations
3. Effective training and tools for GE operations
4. Metrics

Team

GE’s EHS team is led by Vice President for EHS Ann Klee. Klee and the EHS leaders from each business meet twice each year to discuss programs and priorities and to exchange best practices. GE operates 10 task forces—on topics such as industrial hygiene, air, water and ergonomics—with cross-business participation. GE also operates 16 geographically focused, cross-business EHS networks for our EHS professionals in places where GE has a significant presence, including Mexico, Southeast Asia, China and Europe. In addition, working groups are established to tackle challenging cross-business issues such as process safety management, dealing with lower-risk operations, and management of change. Ultimate responsibility for EHS performance resides with business leaders, including plant managers and service operations leaders who are supported by more than 1,000 GE EHS professionals.

Programs

To ensure consistent global standards, GE has developed “EHS Frameworks” consisting of 27 elements, including more than 680 questions and guide notes to serve as a Web-based multilanguage tool that combines “how-to” information with methods of evaluation. These tools have been incorporated into Gensuite^®, a Web-based EHS data management system developed by GE and translated into 12 languages.

To facilitate compliance with tens of thousands of EHS laws and regulations across the entire range of GE’s operations throughout the world, the Company regularly updates Web-based modules containing EHS legal requirements in 51 jurisdictions in 13 languages. We have also developed more than 800 multilingual training courses, translated into 24 languages. In 2011, our training objectives include focusing on EHS knowledge and skill-building for specific jobs, consolidating and streamlining course content, broadening the availability of environmental compliance and management system training, and enhancing the rigor of the training development and assignment process.

One of the ways in which GE differentiates its EHS compliance is by training operations leaders on their responsibilities through EHS Operations Leadership Training. In 2010, GE conducted more than 25 sessions of this course globally, including offering our first course in Africa, to meet GE’s growth in the region. During a two-day interactive course, attendees learn about the Company’s EHS expectations, how to demonstrate leadership and how to create top-level EHS performance. Most important, employees interact with their peers and come away with action plans to implement when they return to their operations. In 2010, particular focus was given to how leaders can help manage change in operations to prevent EHS issues, as well as to discrete actionable steps leaders can take to demonstrate their commitment to, and engage with, their employees in EHS.

Each quarter, a GE EHS Scorecard goes to GE’s chief executive officer and other top leaders showing individual business performance on key metrics, including injuries, lost time rates, environmental exceedances and penalties.

GE has instituted a due diligence and transaction review process to ensure that the risks of remedial and other environment, health and safety liabilities are carefully reviewed and factored into any potential transaction or disposition. There is a review process in each business that is coordinated and overseen by Corporate Environmental Programs to provide consistency and accountability. At the corporate level, a team of EHS professionals provides additional support on significant transactions, including working with the businesses to develop remedial plans if needed and integration plans to help newly acquired operations implement GE’s EHS management systems.

GE uses several assurance mechanisms to confirm compliance in meeting GE global expectations. GE does this through a robust EHS management system and several other practices including:

• Ongoing self-assessments to identify and promptly fix compliance issues. Findings are entered into a companywide database that tracks them to closure and alerts management of those that are not promptly addressed.
• Regular business-level audits on a cycle set by the businesses and agreed to by the corporate team that provide oversight and confirmation of compliance with law and implementation of GE best practices and programs.
• Ongoing tracking of compliance findings identified by GE locations.
• Review of audit findings and processes in annual EHS operating reviews.
• Gensuite^® applications that allow locations to closely track all permit and inspection requirements.
• A requirement that 90% of compliance findings be closed within 30 days and 100% within 180 days. During 2010, 96% were closed within 30 days. Only seven findings were open for more than 180 days. This findings requirement demonstrates how GE continues to raise its own bar. Until 2003, the requirement was to close 90% of findings in 60 days.
• Third-party audits each year to qualify specific environmental management systems for certification by the International Standards Organization and for safety excellence certification in the United States, Mexico and the Province of Alberta health and safety excellence programs.
• Monitoring of results by operations and EHS leadership through digital cockpits.