Sima Solutions

Internal Environmental Management System

Prepared for:

IBM

Introduction

Sima Solutions is currently in the planning stages of mapping our systemic approach to sustainability through development of an Environmental Management System (EMS). Our EMS will follow 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 SIMA SOLUTIONS’s developing EMS will comply 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.

SIMA SOLUTIONS Compliance: The fulfillment of requirements 2-8 will satisfy the need for an environmental management system. Additionally, SIMA SOLUTIONS will post a sustainability statement on our website.

The code of conduct requirement will be fulfilled by posting a list of principles on the company website:

www.simasolutionscorp.com/article

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.

SIMA SOLUTIONS Compliance: SIMA SOLUTIONS 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.

SIMA SOLUTIONS Compliance: SIMA SOLUTIONS at this time cannot acquire accurate measurement of energy usage and or greenhouse Gas emissions. The reason for this is that Sima Solutions lease office space from a Executive Suite company that manages an entire floor of a large building. The building management and the executive suite company can only measure the entire building usage up to a specific floor at a time. The corporate headquarter office located at 1 Lincoln Centre Oak Brook Terrace, Illinois 60181 can be contacted for more detailed contact information on whom to speak with at the building location and or the executive suite company manager. We currently only utilize one single office and our consultants work on site at client locations.

What Sima Solutions does as a company to conserve energy and contribute to the environment well-being is the following:
We turn off lights any time we are going to be out of our office for any period longer than 1 hour
We turn off our computers every night and any time we are going to be away for longer than 2 hours from the computer.
We recycle all of our papers through placing them in recycling bins or shredding sensitive information documents.

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 1 and scope 2 greenhouse gas emissions

· Waste management and recycling.

SIMA SOLUTIONS Compliance: SIMA SOLUTIONS Challenges and requires all employees and . The goal measuring period will be 12 months.

Due statement in section 3 we cannot currently measure energy. ( See section 3 statement) We will continue to pursue the ability to measure these listed areas and plan on having the abililty to measure them by end of 2011.

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.

SIMA SOLUTIONS Compliance:

Sima does not publicly disclose annual reports but will publicly disclose any fines/ penalties in the future if they occur related to environmental performance.

The SIMA SOLUTIONS Company website may also be used to publish a mini-sustainability report.

IBM Requirement #6: Train employees who are responsible for performing this work.

SIMA SOLUTIONS Compliance: Once the EMS has been established, SIMA SOLUTIONS Company will share the contents and our goals for environmental conservation with all employees.
Sima requires that its employees and contractors performing work on its behalf at an IBM and or Sima Client location, receive environmental training in the form of information that is commensurate with their responsibilities and includes Sima’s environmental policy and commitment.
Sima ensures that its employees have the appropriate and current knowledge of applicable legal and Sima requirements, and the company’s corporate responsibility & environmental policies and objectives.
Sima communicates to its suppliers (contractors/vendors) -- that:

Ø suppliers are to educate their employees relevant to applicable environmental requirements,

Ø suppliers are to regularly check in with their consultants and employees that they are

up to date with the latest policies related to Environmental Management

IBM Requirement #7: Conduct self-assessments and audits as well as management reviews.

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

· Senior management representative

· Building/office manager

· Accounting/auditing manager

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.

SIMA SOLUTIONS Compliance: SIMA SOLUTIONS will publish our EMS statement and brief description of these requirements on our supplier website. Suppliers will be encouraged to establish their own EMS programs within their respective organizations.

Timeline

SIMA SOLUTIONS Company’s EMS is on target to be deployed at the corporate headquarters level by the end of 2011. We will take a phased approach to rolling out the EMS, with a target date of December 31, 2011 at the latest. The final EMS approach will be cascaded to our subsidiaries.