functions. The term should be reserved for systematic and objective evaluations that are carried out by experts who are independent of the function or location being audited. Corporate auditing, as conducted by Ciba, is a strategic management tool; it helps to ensure compliance with current legal and regulatory requirements to minimize future risks and liabilities through a proactive approach that focuses on anticipating future requirements. Also, Ciba's approach to auditing helps to increase operating efficiency, effectiveness, and quality because it not only addresses management and control systems, but also technical, organization, and personnel issues. In summary, auditing does not simply provide a picture of a location's compliance status, it identifies weaknesses and vulnerabilities regarding continued compliance, either with today's or anticipated standards.

For any large manufacturing company, it is neither possible nor appropriate to conduct meaningful annual audits of manufacturing facilities, even the major ones. A number of audit findings may require significant effort by the facility to resolve, and it is appropriate to provide at least 2 years between audits to allow progress to be made. Also, compliance is the line responsibility of each facility, and conducting audits too frequently would tend to shift accountability for compliance from the facility to the auditors.

In addition to the information from audits, Ciba senior management needed an annual, worldwide survey to provide meaningful information on safety, energy consumption, and environmental performance. This information was needed to help set annual and periodic priorities for initiatives to improve worldwide performance in these areas. Therefore, in 1990 Ciba introduced annual reports on safety, energy, and environmental performance (commonly known as SEEP reports) to obtain accountability of safety, energy conservation, and environmental protection performance; determine performance criteria for sites; serve as a management tool; and provide information for communicating corporate performance.

For many years, Ciba's worldwide production facilities provided environmental reports to their site, national (group company), and worldwide corporate managements. However, these reports were not always comparable because they were based on the information needs of local management and the legal requirements of individual countries. These reports were of interest to the worldwide corporate headquarters, but because of their varying formats, it was not possible to consolidate the reported data to gain information on worldwide corporate performance.

In 1990, a corporatewide standardized reporting system was established, known as the annual SEEP report. All major production sites are required to complete the report, whereas submission by other sites is at the discretion of the head of the group company. The number of sites submitting SEEP reports rose