The foundation of Bristol-Myers Squibb’s EHS program is to fully comply with government regulations and worldwide corporate directives designed to help protect the environment, our workers and the public.

Bristol-Myers Squibb tracks EHS citations, administrative orders and similar notifications worldwide as a result of government interactions and inspections. Whenever a facility does not meet a regulatory requirement, management determines the cause of the noncompliance, takes appropriate corrective measures, and, if necessary, develops an action plan to prevent its recurrence.

There were about 110, 80 and 90 government-initiated interactions in 2009, 2010 and 2011 respectively (including, but not limited to, site visits or inspections) at Bristol-Myers Squibb facilities relating to EHS. In 2011 there were about 35 safety and 55 environmental-related government interactions.

The global reporting information provided below reflects only penalties associated with government inspections and does not include, for example, self-reported permit exceedances or minor administrative errors. Also, fines associated with a violation are assigned to the year the fine was paid.

Recent Citations History

The number of EHS citations issued to Bristol-Myers Squibb was 22, 20 and 19 in the years 2009, 2010 and 2011, respectively. In 2011, thirteen citations were safety-related and six were environmental-related. Fines and penalties over $100K paid by the company are disclosed in the annual 10K report filed with the SEC. The company reported one event for $127,000 in 2009 and none in 2010 and 2011.

Reportable Spills

All Bristol-Myers Squibb facilities maintain a spill prevention and response plan to minimize and properly manage any spill or unintended release to the environment.

Bristol-Myers Squibb, like most major industrial companies, is involved in a number of environmental cleanups associated with past activities. We invest resources to achieve cleanup in a manner that is environmentally and financially responsible. We utilize risk management techniques whenever possible to determine the most effective approaches to pursue at each cleanup site. Our prevention-based initiatives, such as product life cycle reviews and best practices transfer, minimize the potential for future environmental impacts.

Bristol-Myers Squibb’s EHS and legal staff routinely interact with Potentially Responsible Parties, government agencies and community groups toward the common goal of providing cost-effective remediation that protects human health and the environment.

Through the end of 2011, Bristol-Myers Squibb estimates its share of the total future costs for these sites is approximately $69.4 million. In 2011, the company paid approximately $3.7 million (excluding legal fees) for investigation and remediation of such matters, including liabilities under CERCLA, state and other regulatory authorities. The company had paid approximately $3.9 million in 2010.

Investigation/remediation projects were ongoing at the following Bristol-Myers Squibb operating facilities in 2011:

• Humacao, Puerto Rico
• New Brunswick, New Jersey
• São Paulo, Brazil
• Swords, Ireland
• Syracuse, New York