Environment, Health & Safety Compliance

Being part of a community means taking care of each other and our environment. For AT&T, this means we are committed to complying with all applicable environment, health and safety (EHS) laws and regulations pertaining to our operations and the geographies where we work. It also means developing and maintaining the right systems to protect our environment and our employees.

Everyone at AT&T has a role to play in protecting our environment and upholding safety standards. From our part-time workers to our CEO, employees are responsible for reviewing the AT&T Code of Business Conduct (COBC) annually and understanding its provisions. EHS considerations, such as minimizing and recycling waste, are integrated into our business processes to conserve natural resources and prevent pollution. We also encourage our suppliers and contractors to integrate EHS considerations into their processes through our contract language and our requirement to adhere to the AT&T Principles of Conduct for Suppliers.

Due to the complex nature of our operations, the content of this issue brief will reflect AT&T Communications unless otherwise noted. For more information on our COBC, please visit our Ethics & Integrity issue brief.

In 2022, AT&T’s EHS strategy focused on improving data management to streamline data collection and boost analysis, and ultimately better safeguard the health and safety of our employees while limiting our environmental impact. This included:

• Optimizing several modules within our Compliance Data Management System to improve data tracking and gain efficiencies through programs and process improvements.
• Establishing an Internal Operating Procedure for conducting focused reviews of specific EHS programs and enhancing the feedback loop with appropriate stakeholders.
• Transitioning EHS training records to a new platform, allowing for better tracking and management of required training based on job function.
• Designing and implementing a new governance process to keep senior leaders at AT&T apprised of EHS performance and compliance status for their respective business units.
• Implementing a new Document Management System to facilitate better tracking of document owners and revisions and archiving of obsolete documents.

Governance

• Assistant Vice President—EHS: This position is the lead for our EHS Management System and reports to the Vice President of Global Real Estate.
• EHS Leadership Team: This team, which includes senior leaders from across our EHS department, periodically evaluates EHS programs based on data collected from reviews, audits and new regulatory requirements. Based on this analysis, they develop strategies and plans to improve the management system and compliance programs as part of the organizational goals and EHS plans.
• EHS Governance Team: Working closely with the EHS Leadership team, this group coordinates cross-functional engagement with EHS goals, compliance and action planning. In addition to the development of strategies to improve the EHS Management Systems and compliance with EHS, they provide information and updates to key business unit stakeholders throughout the year.
• Compliance: Our Chief Compliance Office organization assists the EHS Leadership team in managing key EHS risks, providing risk oversight and holding monthly calls to discuss current and emerging EHS issues.
• Business Unit Stakeholders: This group is comprised of senior leaders from across AT&T’s business units and periodically evaluates strategic annual goals (EHS plans) set by EHS and business units. They also assess applicable corrective actions to minimize risk to the corporation.

Environment, Health & Safety Management System

AT&T Communications adopted an Environment, Health and Safety Management System based on the principles of International Organization for Standardization (ISO) and Occupational Health and Safety Assessment Series (OHSAS). Details of our EHS Management System are listed in the following sections.

EHS Policies, Planning, Implementation & Evaluation

The EHS Management System provides a framework for AT&T to systematically manage our environmental risks and health and safety hazards and ensure compliance with external and internal objectives. In doing so, this system helps us improve our operations and performance while maintaining the highest commitment to the health and safety of our employees and protection of the environment. It consists of the following elements:

• Environment, Health & Safety Policy: The AT&T Environment, Health & Safety Policy reflects our responsibility to comply with EHS laws and regulations, continuously improve our management systems and achieve other nonregulatory EHS goals. This policy commits all AT&T business units and operating companies worldwide to operate in an environmentally responsible manner and to protect the health and safety of our employees and the public. We updated the policy in 2020 to further align with the evolving needs of our business.
• Planning: We proactively identify potential hazards, risks and environmental impacts associated with our operations. When a new process or task is identified, an EHS professional with knowledge of the work activity performs a hazard assessment and determines what personal protective equipment (PPE), if any, should be required. We maintain assessment results in an online system that helps us design and prioritize programs and processes to prevent or mitigate the potential hazards and risks identified. As part of our planning, we establish annual objectives and targets to measure and improve EHS performance. Our Business Continuity Preparedness Handbook provides an overview of best practices to facilitate proactive planning and ongoing enforcement for all event scenarios. We consider the use of PPE a last line of defense, as first emphasis is given to engineering or administrative controls that can eliminate such a need. We manage compliance by implementing business unit EHS plans and analyzing audit and assessment data.
• Annual Targets: Each year, our EHS team partners with business unit representatives to establish targets for reducing personal injury accident and motor vehicle accident rates where applicable. These targets—and the strategies for achieving them—are incorporated into each business unit’s annual EHS plan. Progress is reviewed at least quarterly with the business units. We also track the number of hours our employees spend on training and set targets with the purpose of reducing health and safety incidents. In 2022, we transitioned our EHS training records to a new platform, allowing for better tracking and management of required training based on job function.
• Implementation: We implement EHS plans by setting targets and deadlines, assigning clear responsibility and accountability for EHS performance, and defining roles and responsibilities within the EHS organization. We provide EHS information and resources both within and outside the enterprise by training AT&T employees and communicating EHS expectations to our vendors and contractors. This includes providing employees with resources and information on best practices to prevent workplace exposure to COVID-19 and other transmittable diseases. We encourage managers to directly engage with and hold their teams accountable for supporting employee participation in EHS program development activities. We are also optimizing several modules within our Compliance Data Management System to improve data tracking and gain efficiencies through programs and process improvements. We also are implementing a new Document Management System to facilitate better tracking of document owners and revisions and archiving of obsolete documents.
• Evaluation: AT&T evaluates EHS performance with varying frequency, from monthly to quarterly, depending on the business unit and type of work performed. Our evaluations analyze key performance measures and metrics covering most of AT&T and review business operations that impact EHS. If we identify incidents or noncompliance with laws or company standards, we have formal systems in place to identify corrective actions and track these actions until they are completed.
  • As an example of our evaluations, AT&T Communications completed over 3,472 internal Environmental Site Assessments (ESAs) at 3,017 locations in 2022. ESAs are focused on compliance with environmental regulations, such as hazardous material storage and air emissions. We use a risk-based approach to determine the location and frequency of ESAs.
  • Monitoring for health and safety performance is outlined in each business unit’s annual EHS plan. AT&T conducts internal health and safety observation and competency checks. The subject and frequency of these reviews are based on risks and established through annual, department-specific EHS plans and targets, focusing on groups that have the greatest opportunity for improvement. Corporate EHS monitors the effectiveness of department-specific plans and works with each business unit to drive improvement.
  • In 2022, we worked to establish an Internal Operating Procedure for conducting focused reviews of specific EHS programs and enhancing the feedback loop with appropriate stakeholders.
• External Review: In 2022, we completed a comprehensive external review of our EHS Management System. We are currently working to update the document per recommendations and are targeting Q2 2023 for completion. Evaluation of ISO and OHSAS certifications were deferred to 2023.
• Employee & Stakeholder Reporting: As part of our overall EHS Management System, we maintain a toll-free number (800-KNOW-EHS) for employees, contractors and the general public to call regarding EHS-related issues such as hazardous material spills and employee health and safety incidents. Each call is managed by an EHS representative, documented in our EHS Incident Tracking System and tracked to resolution. Response times vary depending on the type of incident and regulatory requirements. Incidents that are not handled within expected time frames are escalated to leadership.
• Oversight: AT&T senior leadership participates in regular reviews of our EHS performance and programs. The Assistant Vice President—EHS is the lead for our EHS Management System and reports to the Vice President of Real Estate Operations. In 2022, we designed and implemented a new governance process to keep senior leaders at AT&T apprised of EHS performance and compliance status for their respective business units.

Environment, Health & Safety Inspections

AT&T is subject to environmental inspections performed by government agencies to remain in compliance with applicable EHS laws and regulations. Enforcement actions and total fines for 2022 are detailed below:

• Government Agency Environmental Inspections: AT&T Communications underwent 2,935 environmental inspections by government agencies in 2022, resulting in 7 enforcement actions, all of which resulted in a penalty. In 2022, we paid a total of $20,709.91 in fines.⁷
• Voluntary Environmental Disclosures: In 2022, AT&T agreed to pay $5.9 million in monetary relief to the state of California related to a voluntary disclosure to CalEPA, CalFire and the Governor’s Office of Environmental Science after identifying a misapplication of hazardous material inventory reporting in 2019.
• Government Agency Health & Safety Inspections: We underwent 102 health and safety inspections by government agencies in 2022, resulting in 1 enforcement action and a penalty. In 2022, we paid a total of $47,241.90 in fines.⁷
• Hazardous Material Spills: We sustained 560 spills of hazardous materials in 2022, which generated approximately 27 metric tons of waste; 38 of those spills required reporting to a regulatory agency.⁸
• Internal Operation Reviews: We evaluate our EHS performance through regular reviews and internal assessments of our operations. The frequency of these assessments depends on the level of risk identified after evaluating the potential for personal injury, property damage and community or financial impact.
• Internal Evaluation: AT&T Communications internally audited the EHS Management System, covering 100% of its domestic operations in 2017. In 2022, EHS completed a full evaluation of the management system. We are currently working toward completing a revised EHS Management System practice. This document outlines our EHS processes and procedures.

Occupational Health & Safety

We ensure that safety and environmental responsibility are part of every employee’s standard operating procedure.

If an accident occurs in the workplace, our policy is to respond swiftly, investigate contributing factors, determine the root cause and take appropriate corrective actions as detailed below:

• Injury Investigation: Hospitalizations and fatalities associated with a work-related incident are automatically routed to AT&T Corporate EHS Field Support for investigation, analysis and subsequent development of a corrective action plan if certain qualifying factors are identified during the investigation. The analysis identifies key contributing factors and assigns interventions at varying levels (e.g., local, organizational or policy-related) to prevent the recurrence of similar incidents.
• Injury Reporting: We track key metrics to evaluate performance and report incidents as required. Our 2022 performance is outlined below:
  • In 2022, AT&T Communications’ Occupational Safety and Health Administration (OSHA) total recordable incident rate was 1.29 per 100 employees.⁶ This rate is lower than the most recent (2021) employee average published by the Bureau of Labor Statistics for the telecommunications industry, which was 1.7 per 100 employees.⁹
  • In 2022, AT&T Communications had 3 work-related incidents that resulted in fatalities, 1,430 incidents resulting in lost time and 257 incidents that resulted in job restrictions or transfer. In 2022, our Days Away Restricted or Transferred rate, which is also known as Lost Time Incident Rate, was 1.11 per 100 employees.⁶

• We will continue to incorporate environmental compliance into our governance process with business unit leadership, which has traditionally focused on health and safety components. This will help enhance our reporting and help us meet our goal to transparently communicate all measures of EHS performance and drive accountability.
• Regulatory requirements continue to change over time. To ensure that we stay on top of AT&T’s compliance status with the latest regulations, we are undergoing an effort to enhance our corporate EHS database by executing the remaining modules of our Compliance Data Management System.
• We continue to identify and implement reporting tools to optimize EHS data analytics and increase access to EHS compliance data.

• AT&T Code of Business Conduct
• AT&T Environment, Health & Safety Policy
• AT&T Principles of Conduct for Suppliers
• Business Continuity Preparedness Handbook
• Environment, Health and Safety Management System Manual