GRI Index KEY. 1. Strategy and Analysis. 2. Organizational Profile
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1 Varian Sustainability Report 2014 GRI Index The Global Reporting Initiative (GRI) is a not-for-profit organization that promotes sustainability. It provides a comprehensive reporting framework that enables all companies and organizations to disclose their sustainability performance. Varian has achieved an Application Level B. This has been checked by the GRI in accordance with the required disclosures, as described in the GRI G3 Guidelines. KEY FULLY REPORTED PARTIALLY REPORTED NOT REPORTED 1. Strategy and Analysis PROFILE DISCLOSURE LEVEL LOCATION OF DISCLOSURE 1.1 Statement from the most senior decision-maker of the organization. From our CEO, p3 1.2 Description of key impacts, risks, and opportunities. Weaving sustainability into business strategy, p5 6 Health access and outcomes Our approach, p17 Safety and responsibility Our approach, p Annual Report: Form 10-K Item 1A, p Organizational Profile PROFILE DISCLOSURE LEVEL LOCATION OF DISCLOSURE 2.1 Name of the organization. Front cover 2.2 Primary brands, products, and/or services Annual Report: Form 10-K Item 1: Business, p Operational structure of the organization, including main divisions, operating companies, subsidiaries, and joint ventures Annual Report: Form 10-K Item 1: Business, p Location of organization's headquarters. 2.5 Number of countries where the organization operates, and names of countries with either major operations or that are specifically relevant to the sustainability issues covered in the report Nature of ownership and legal form Annual Report: Form 10-K Item 1: Business, p Markets served (including geographic breakdown, sectors served, and types of customers/beneficiaries) Annual Report, p7 Read more at: 1
2 2.8 Scale of the reporting organization., p Annual Report: Form 10-K Item 1: Business, p1 13, p43, p Significant changes during the reporting period regarding size, structure, or ownership. There have not been any significant changes during the reporting period Awards received in the reporting period. Safety and responsibility Radiation safety award for China operation, p Report Parameters PROFILE DISCLOSURE LEVEL LOCATION OF DISCLOSURE 3.1 Reporting period (e.g., fiscal/calendar year) for information provided. October 2012 to September Date of most recent previous report (if any). The previous report was launched in August responsibility.html 3.3 Reporting cycle (annual, biennial, etc.). Annual 3.4 Contact point for questions regarding the report or its contents. 3.5 Process for defining report content. Weaving sustainability into business strategy, p5 6 In 2011, independent sustainability experts BSR ran an in-depth materiality process and held a series of workshops with business and corporate leaders at Varian. This process yielded the four thematic areas that we continue to report to: health access and outcomes, safety and responsibility, environment, and colleagues and communities. The sustainability team reviews this on an annual basis to ensure the thematic areas and content still reflect the key issues for the business and Varian s stakeholders. On pages 8, 16, 23 and 29 we have shown how the business strategy aligns and supports the four thematic areas. The primary stakeholders for the report are ESG-focused investors, employees, and customers. 3.6 Boundary of the report (e.g., countries, divisions, subsidiaries, leased facilities, joint ventures, suppliers). See GRI Boundary Protocol for further guidance. 3.7 State any specific limitations on the scope or boundary of the report (see completeness principle for explanation of scope). 3.8 Basis for reporting on joint ventures, subsidiaries, leased facilities, outsourced operations, and other entities that can significantly affect comparability from period to period and/or between organizations. 3.9 Data measurement techniques and the bases of calculations, including assumptions and techniques underlying estimations applied to the compilation of the Indicators and other information in the report. Explain any decisions not to apply, or to substantially diverge from, the GRI Indicator Protocols Explanation of the effect of any re-statements of information provided in earlier reports, and the reasons for such re-statement (e.g., mergers/acquisitions, change of base years/periods, nature of business, measurement methods) Significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report Table identifying the location of the Standard Disclosures in the report Policy and current practice with regard to seeking external assurance for the report. The report covers 100% of Varian s direct business operations, including leased facilities and suppliers. Varian covers the full scope of sustainability topics relevant to the business and its stakeholders. These have been split into four thematic areas. The boundaries of the report have also been clearly stated in 3.6 and 3.8. Varian reports on leased facilities. In 2013, we expanded the boundary of our emissions inventory. Environment Environmental initiatives across the globe, p25 There are no significant changes in the scope, boundary, or measurement methods applied. GRI Index The report is not externally assured. Read more at: 2
3 4. Governance, Commitments, and Engagement PROFILE DISCLOSURE LEVEL LOCATION OF DISCLOSURE 4.1 Governance structure of the organization, including committees under the highest governance body responsible for specific tasks, such as setting strategy or organizational oversight. 4.2 Indicate whether the Chair of the highest governance body is also an executive officer. 4.3 For organizations that have a unitary board structure, state the number of members of the highest governance body that are independent and/or non-executive members. 4.4 Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body. 4.5 Linkage between compensation for members of the highest governance body, senior managers, and executives (including departure arrangements), and the organization s performance (including social and environmental performance). 4.6 Processes in place for the highest governance body to ensure conflicts of interest are avoided. 4.7 Process for determining the qualifications and expertise of the members of the highest governance body for guiding the organization s strategy on economic, environmental, and social topics. Members of the governance body are selected based on role rather than personal expertise. As this is a company-wide program, Varian considers it vital that the leaders of the three business units are actively involved, along with the senior corporate leaders, particularly the CEO, CFO and General Counsel. More information about the Board and committees can be found online in the Corporate Governance section: CorporateGovernance 4.8 Internally developed statements of mission or values, codes of conduct, and principles relevant to economic, environmental, and social performance and the status of their implementation. 4.9 Procedures of the highest governance body for overseeing the organization s identification and management of economic, environmental, and social performance, including relevant risks and opportunities, and adherence or compliance with internationally agreed standards, codes of conduct, and principles Processes for evaluating the highest governance body s own performance, particularly with respect to economic, environmental, and social performance Explanation of whether and how the precautionary approach or principle is addressed by the organization Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organization subscribes or endorses Memberships in associations (such as industry associations) and/ or national/international advocacy organizations in which the organization: * Has positions in governance bodies; * Participates in projects or committees; * Provides substantive funding beyond routine membership dues; or * Views membership as strategic. From our CEO, p3 Varian s values, p33 Safety and responsibility Our approach, p17 More information about the Board and committees can be found online in the Corporate Governance section: CorporateGovernance Senior leaders in the company are rewarded for growing operating profit dollars. Varian views effective CSR as beneficial to the bottom line optimized ESG activities can have significant cost-saving and efficiency benefits. Ultimately, the governance committee will be rewarded for such efficiency savings. However, there is no formal evaluation program on their performance in this area. Varian is in the business of helping to save lives; we are a risk adverse business. We therefore adopt the precautionary approach: where there may be threats of serious or irreversible impact but a lack of full scientific certainty, we will not use this as a reason for postponing cost-effective measures to prevent negative or harmful environmental or social impacts. UICC World Cancer Declaration Carbon Disclosure Project Global Reporting Initiative IAEA PACT Program ASTRO gold membership ESTRO gold membership 4.14 List of stakeholder groups engaged by the organization. Customers, patients, communities, investors, suppliers, employees, academics/ medical research community, regulators, policymakers 4.15 Basis for identification and selection of stakeholders with whom to engage. Stakeholders have been identified on the basis of who Varian as a business affects and engages with the most with respect to financial, social, and environmental matters. Read more at: 3
4 4.16 Approaches to stakeholder engagement, including frequency of engagement by type and by stakeholder group. From our CEO, p3 Varian s values, p33 Health access and outcomes Our approach, p9 Safety and responsibility Collaboration on safety, p19 Safety and responsibility Products and safety, p20 Safety and responsibility Research and development, p21 We engage with our stakeholders formally and informally through our business activities. The key stakeholders for Varian s annual Sustainability Report are investors and employees. Varian engages with the growing number of ESG-focused investors, particularly in Europe, through presenting at ESG/CSR financial events, targeting relevant new investors, and communicating regularly with existing ESG-focused investors such as Generation (London) and PGGM (Amsterdam), both of whom are among Varian s top 10 global investors. Latest results of a customer satisfaction survey are available at newsroom.varian.com/index.php?s=31868&item= Key topics and concerns that have been raised through stakeholder engagement, and how the organization has responded to those key topics and concerns, including through its reporting. From our CEO, p3 Varian s values, p33 Safety and responsibility Collaboration on safety, p19 Safety and responsibility Products and safety, p20 Safety and responsibility Research and development, p21 Disclosure on Management Approach EC Economic performance Market presence Health access and outcomes Our approach, p Annual Report: Form 10-K, p Annual Report: Form 10-K p70 71, p Annual Report: Form 10-K, p7 12 Indirect economic impacts Health access and outcomes, p8 15 Safety and responsibility, p16 22 Colleagues and communities, p29 33 Disclosure on Management Approach EN Materials Energy Water Emissions, effluents and waste Products and services 2014 CDP Water Disclosure report 2013 Annual Report: Form 10-K, Note 9: Commitments and contingencies, p93 94 Compliance 2013 Annual Report: Form 10-K, p22 24 Environment Update on ROHS and WEEE, p28 Transport Overall Disclosure on Management Approach LA Employment 2013 Annual Report: Form 10-K, p17 Read more at: 4
5 Labor/management relations Occupational health and safety Training and education Diversity and equal opportunity 2013 Annual Report: Form 10-K, p17 Safety and responsibility Our approach, p Annual Report: Form 10-K, p Disclosure on Management Approach HR Investment and procurement practices Non-discrimination Freedom of association and collective bargaining Child labor Forced and compulsory labor Varian is in the business of helping to save lives. We are, therefore, committed to upholding human rights. Varian is also currently developing a policy on conflict minerals to ensure that its supply chain does not contribute to loss of human life. Code of conduct 2013 Annual Report: Form 10-K, p17 No operations have been identified with significant risks for child labor. No operations have been identified with significant risks for forced or compulsory labor. Disclosure on Management Approach SO Community Health access and outcomes Our approach, p9 Corruption 2013 Annual Report: Form 10-K, p27 28 Further information is provided under indicators SO2 and SO3. Public policy This information can be found under indicators SO5 and SO6. Anti-competitive behavior 2013 Annual Report: Form 10-K, p27 28 Compliance 2013 Annual Report: Form 10-K, p27 28, p13 16 Disclosure on Management Approach PR Customer health and safety Product and service labelling Safety and responsbility Our approach, p Annual Report: Form 10-K, p13 14, p16, p22, p24 Marketing communications 2013 Annual Report: Form 10-K p22 25 Customer privacy 2013 Annual Report: Form 10-K, p25 Compliance 2013 Annual Report: Form 10-K, p13 14, p22 25 Read more at: 5
6 Performance Indicators PROFILE DISCLOSURE LEVEL LOCATION OF DISCLOSURE ECONOMIC ECONOMIC PERFORMANCE EC1 Direct economic value generated and distributed, including revenues, operating costs, employee compensation, donations and other community investments, retained earnings, and payments to capital providers and governments. EC2 Financial implications and other risks and opportunities for the organization's activities due to climate change Annual Report: Form 10-K, Results of Operations, p Annual Report: Form 10-K, Item 8: Financial statements and supplementary data, p69 73 EC3 Coverage of the organization's defined benefit plan obligations Annual Report: Form 10-K, Item 8: Financial statements and supplementary data, p70, p EC4 Significant financial assistance received from government. Varian does not receive financial assistance from the government. MARKET PRESENCE EC5 EC6 Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation. Policy, practices, and proportion of spending on locally based suppliers at significant locations of operation. Varian continues to emphasize that our employees are our most important asset. We have a philosophy of paying fairly and rewarding for performance. In 2013, we rolled out a personal comprehensive compensation statement for each U.S. employee to show them how the company supports them through 401k match and employer subsidized benefits, in addition to regular salary and bonuses. We hope to be able to roll out a similar statement worldwide in the near future. Varian promotes the use of local suppliers where possible. For example, at Varian s Crawley facility 60% of suppliers come from the surrounding area. INDIRECT ECONOMIC IMPACTS EC8 ENVIRONMENTAL ENERGY Development and impact of infrastructure investments and services provided primarily for public benefit through commercial, in-kind, or pro bono engagement. Health access and outcomes, p8 15 Safety and responsibility Our approach, p17 EN3 Direct energy consumption by primary energy source. EN5 Energy saved due to conservation and efficiency improvements. Environment, p24 25 EN6 WATER Initiatives to provide energy-efficient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives. Environment Environmental initiatives across the globe, p25 EN8 Total water withdrawal by source. CDP Water submission 2014 EMISSIONS, EFFLUENTS AND WASTE EN16 Total direct and indirect greenhouse gas emissions by weight. Environment Environmental initiatives across the globe, p25 EN17 Other relevant indirect greenhouse gas emissions by weight. Environment Environmental initiatives across the globe, p25 EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved. Environment, p25 28 EN20 NOx, SOx, and other significant air emissions by type and weight. Environment Environmental initiatives across the globe, p25 EN21 Total water discharge by quality and destination. Storm water is typically discharged through municipal storm water conveyance systems. Sanitary and industrial wastewater discharges are sent to the local Publicly Owned Treatment Works (POTW) for treatment. These discharges are regulated by the POTW. Varian does not discharge directly to any body of water, such as a river, stream, lake, ocean. EN22 Total weight of waste by type and disposal method. Environment Update on ROHS and WEEE, p28 Read more at: 6
7 EN23 Total number and volume of significant spills. We disclose any material current spills in the company s Annual Report on Form 10-K for the applicable fiscal year. For the reporting period, please see the company s Annual Report on Form 10-K for our fiscal year 2013, Part I Business. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no significant spills reported. EN24 Weight of transported, imported, exported, or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, and VIII, and percentage of transported waste shipped internationally. PRODUCTS AND SERVICES EN26 EN27 Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation. Percentage of products sold and their packaging materials that are reclaimed by category. Environment Environmental initiatives across the globe, p25 Environment, p Annual Report: Form 10-K, Note 9: Commitments and contingencies, p93 94 Environment Recycling, p28 COMPLIANCE EN28 Monetary value of significant fines and total number of nonmonetary sanctions for non-compliance with environmental laws and regulations. TRANSPORT EN29 Significant environmental impacts of transporting products and other goods and materials used for the organization s operations, and transporting members of the workforce. We disclose any material current fines and sanctions for non-compliance with environmental laws and regulations in the company s Annual Report on Form 10- K for the applicable fiscal year. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified material fines and sanctions for non-compliance with environmental laws and regulations. Environment Environmental initiatives across the globe, p25 OVERALL EN30 Total environmental protection expenditures and investments by type. SOCIAL: LABOR PRACTICES AND DECENT WORK EMPLOYMENT LA1 Total workforce by employment type, employment contract, and region. LA2 Total number and rate of employee turnover by age group, gender, and region. Almost $230,000 has been invested in energy efficiency and fugitive emission reduction measures across Varian s buildings and operations (according to the CDP submission) Annual Report: Form 10-K, p17 Varian has approximately 6,700 employees globally. Approximately 74% of our employees are men, reflecting the large service organization and engineering focus we have. Geographically, we have employees in 32 countries with the Americas (U.S., Canada, Brazil) representing about 60% of our employee base, Europe (including Russia) representing 30% of our employees, APAC (including Australia) representing 10%. Varian s turnover is less than 8% a year and almost 80% of that is voluntary. The average age of employees is 43 and the average length of service is eight years. LABOR/MANAGEMENT RELATIONS LA4 LA5 Percentage of employees covered by collective bargaining agreements. Minimum notice period(s) regarding significant operational changes, including whether it is specified in collective agreements Annual Report: Form 10-K, p17 We had approximately 6,400 full-time and part-time employees worldwide, including 3,700 in the United States and 2,700 elsewhere at September 27, None of our employees based in the United States are unionized or subject to collective bargaining agreements. Employees based in some foreign countries may, from time to time, be represented by works councils or unions, or subject to collective bargaining agreements. If an employee s position is being changed or eliminated based on operational changes, we comply with the law with respect to notice periods. OCCUPATIONAL HEALTH AND SAFETY LA7 LA8 Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region. Education, training, counseling, prevention, and risk-control programs in place to assist workforce members, their families, or community members regarding serious diseases. Safety and responsibility Health and safety, p22 Health access and outcomes, p8 15 Safety and responsibility, p16 22 Colleagues and communities, p29 33 Read more at: 7
8 TRAINING AND EDUCATION LA10 Average hours of training per year per employee by employee category. LA11 LA12 Programs for skills management and lifelong learning that support the continued employability of employees and assist them in managing career endings. Percentage of employees receiving regular performance and career development reviews. DIVERSITY AND EQUAL OPPORTUNITY LA13 Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership, and other indicators of diversity. Varian employees receive on average approximately 40 hours of training per year. Varian encourages employees to attend external courses or degree programs related to their job or a role they aspire to within the company and provides up to 100% reimbursement for registration, tuition, books, and fees for work-related courses, up to $7,500 per calendar year in the U.S. (outside the policy varies based on local custom and tax treatment) Annual Report: Form 10-K, p In 2012, Varian eliminated formal performance reviews, favoring instead a process of goal cascading and coaching whereby managers and employees meet up to four times per year to discuss progress against goals, development needs, and personal improvement Annual Report: Form 10-K, p17 18, p127 At the top of the company, Varian is well represented from a gender perspective five of the 10 Executive Vice Presidents (VPs) and Senior VPs are women and 20% of all executives (defined as directors and above) are female. Over 50% of our employees are located in the U.S. where we track ethnic diversity. There are two women on Varian s board of directors. LA14 Ratio of basic salary of men to women by employee category. Varian pays fairly based on the experience, performance and skillset of the individual. SOCIAL: HUMAN RIGHTS INVESTMENT AND PROCUREMENT PRACTICES HR3 Total hours of employee training on policies and procedures concerning aspects of human rights that are relevant to operations, including the percentage of employees trained. All managers are required to take harassment prevention training for a minimum of two hours every other year and all new employees also take a course in harassment prevention. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING HR5 Operations identified in which the right to exercise freedom of association and collective bargaining may be at significant risk, and actions taken to support these rights. No operations have been identified with significant risks for the right to exercise freedom of association and collective bargaining. CHILD LABOR HR6 Operations identified as having significant risk for incidents of child labor, and measures taken to contribute to the elimination of child labor. No operations have been identified with significant risks for child labor. FORCED AND COMPULSORY LABOR HR7 Operations identified as having significant risk for incidents of forced or compulsory labor, and measures to contribute to the elimination of forced or compulsory labor. SOCIAL: SOCIETY COMMUNITY SO1 Nature, scope, and effectiveness of any programs and practices that assess and manage the impacts of operations on communities, including entering, operating, and exiting. No operations have been identified with significant risks for forced or compulsory labor. Health access and outcomes, p8 15 Safety and responsibility, p16 22 Environment, p23 28 Colleagues and communities, p30, p32 33 CORRUPTION SO2 SO3 Percentage and total number of business units analyzed for risks related to corruption. Percentage of employees trained in organization's anti-corruption policies and procedures. Safety and responsibility, p17 Varian has a corporate policy on anti-corruption. All of Varian s business units have been analysed for risks related to corruption. Varian has corporate policies on Anti-Corruption and Anti-Kickback/Anti-Fraud. All employees also receive e-learning and live training on these policies. Read more at: 8
9 SO4 Actions taken in response to incidents of corruption. Varian actively monitors and tests Anti-Corruption and Anti-Kickback programs. Incidents and investigation processes are in place to respond to findings. PUBLIC POLICY SO5 SO6 Public policy positions and participation in public policy development and lobbying. Total value of financial and in-kind contributions to political parties, politicians, and related institutions by country. ANTI-COMPETITIVE BEHAVIOR SO7 Total number of legal actions for anti-competitive behavior, antitrust, and monopoly practices and their outcomes. COMPLIANCE SO8 Monetary value of significant fines and total number of nonmonetary sanctions for non-compliance with laws and regulations. SOCIAL: PRODUCT RESPONSIBILITY CUSTOMER HEALTH AND SAFETY PR1 Life cycle stages in which health and safety impacts of products and services are assessed for improvement, and percentage of significant products and services categories subject to such procedures. Varian Medical Systems engages in advocacy as it relates to expansion of the use of radiotherapy for the treatment of cancer globally. Varian engages with governments to educate on the value of radiotherapy and its role in the treatment of cancer. To further this, Varian advocates to ensure that patients have access to radiotherapy through appropriate reimbursement, that there is funding for procurement and that the regulatory schemes in countries are appropriate. Varian also actively encourages valuable research to take place on Varian machines to improve cancer treatment and inform public policy. Varian has a Political Action Committee in the United States that regularly files reports with the U.S. Federal Election Commission (FEC). All information regarding contribution history is available at the FEC. Varian has not made any contributions to politicians outside the United States. Varian has a corporate policy to provide further guidance on political donations. We disclose any material current legal proceedings in the company s Annual Report on Form 10-K for the applicable fiscal year. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified material legal proceedings for anti-competitive behavior, antitrust, and monopoly practices. We disclose any material current fines and sanctions in the company s Annual Report on Form 10-K for the applicable fiscal year. For the reporting period, please see the company s Annual Report on Form 10-K for our fiscal year 2013, Part I Business and Note 9 Commitments and Contingencies of the Notes to the Consolidated Financial Statements, pages As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified material fines or sanctions for non-compliance with laws and regulations. Safety and responsibility, p16 22 Health access and outcomes, p Annual Report: Form 10-K, p13 14, p16, p22 24 PR2 Total number of incidents of non-compliance with regulations and voluntary codes concerning health and safety impacts of products and services during their life cycle, by type of outcomes. PRODUCT AND SERVICE LABELLING PR3 Type of product and service information required by procedures, and percentage of significant products and services subject to such information requirements. PR4 Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labeling, by type of outcomes. MARKETING COMMUNICATIONS PR6 Programs for adherence to laws, standards, and voluntary codes related to marketing communications, including advertising, promotion, and sponsorship. There have been no incidents of non-compliance with regulation and voluntary codes concerning health and safety impacts of Varian s products and services. Safety and responsibility Our approach, p17 Safety and responsibility Health and safety, p22 Environment Update on ROHS and WEEE, p28 We disclose any material current incidents of non-compliance in the company s Annual Report on Form 10-K for the applicable fiscal year. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified reported incidents of non-compliance with regulations and voluntary codes concerning health and safety impacts of our services Annual Report: Form 10-K, p13 14, p16, p22, p24 We disclose any material current incidents of non-compliance in the company s Annual Report on Form 10-K for the applicable fiscal year. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified material incidents of non-compliance with regulations and voluntary codes concerning product and service information. Varian s marketing program adheres to laws, standards, and voluntary codes related to marketing communications. More information is available here: Annual Report: Form 10-K, p13 14, p16, p22, p24 Read more at: 9
10 PR7 Total number of incidents of non-compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship by type of outcomes. CUSTOMER PRIVACY PR8 Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data. COMPLIANCE PR9 Monetary value of significant fines for non-compliance with laws and regulations concerning the provision and use of products and services. We disclose any material current incidents of non-compliance in the company s Annual Report on Form 10-K for the applicable fiscal year. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified material incidents of non-compliance with regulations and voluntary codes concerning marketing communications. We disclose any material current substantiated complaints in the company s Annual Report on Form 10-K for the applicable fiscal year. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified material substantiated complaints regarding breaches of customer privacy and losses of customer data. We disclose any material current fines in the company s Annual Report on Form 10-K for the applicable fiscal year. As set forth in our Annual Report on Form 10-K for the company s fiscal year 2013, there have been no identified material fines for non-compliance with regulations concerning the products and use of products and services. Read more at: 10
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