Beyond Compliance: Nonproliferation and the Private Sector GRETCHEN HUND AND ANDREW KURZROK
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1 Beyond Compliance: Nonproliferation and the Private Sector GRETCHEN HUND AND ANDREW KURZROK Global Security, Technology and Policy Group Center for Strategic and International Studies June 6, 2013 June 7, 2013 PNNL-SA
2 Outline The Proliferation Threat The Self-Regulation Approach Through Industry s Eyes: Corporate Sustainability Corporate Sustainability and Nonproliferation Steps Forward June 7, 2013 PNNL-SA
3 Pacific Northwest National Laboratory and Industry Nonproliferation PNNL: a U.S. Department of Energy Laboratory 4,500 scientists, engineers and professional staff 2,000+ patents Customers: U.S. Department of Energy, other government, universities, and industry PNNL s work on industry-driven nonproliferation 8 years of R&D, policy analysis, and stakeholder engagement Partners: U.S. Department of Energy s National Nuclear Security Administration and other stakeholders Discussions at the IAEA, NSG, MTCR June 7, 2013 PNNL-SA
4 The Threat Image adapted from: Financial Action Task Force Proliferation Finance Report (2008) PNNL-SA
5 The Threat June 7, PNNL-SA-95363
6 The Self-Regulation Approach Self Regulation: a systematic, voluntary program of actions undertaken by an industry as a whole by individual companies to anticipate, implement or supplement regulatory requirements, generally through the adoption of best practices. Found in many other industries Diamonds Kimberley Process Apparel The Cotton Pledge Chemicals Responsible Care Cement Cement Sustainability Initiative Wood/paper The Forest Stewardship Council Nuclear Power Institute of Nuclear Power Operations (INPO) Commercial Satellites Space Data Association June 7, 2013 PNNL-SA
7 Beyond Compliance: Steps Industry Can Take Corporate Code of Conduct/ Ethics Sector/Industry Working Groups Set Policy/ Guidelines Third Party Establish ISO-Like Guidance ISO-Like Standards Verification & Third Party Verification Spectrum of steps Steps build upon each other June 7, 2013 PNNL-SA
8 Beyond Compliance: Steps the Nuclear Supply Chain Can Take Sector/Industry Working Groups Set Policy/Guidelines Nuclear Power Plant Exporters Principles of Conduct Carnegie Endowment, 2011 Corporate self-management for exporting nuclear power plants Most global reactor vendors are participants Image source: IAEA June 7, 2013 PNNL-SA
9 Defining Corporate Sustainablity Meet the needs of the present without compromising the ability of future generations to meet their own needs Bruntland Commission, 1987 June 7, 2013 PNNL-SA
10 Sustainability Issues and Opportunities Source: Lydenberg, Steve, Jean Rogers, and David Wood. From Transparency to Performance, Harvard University Hauser Center, June PNNL-SA
11 Sustainability Supply Based on transparency Standard reporting frameworks allow apples-to-apples comparisons between firms Investors, lenders, consumers, public interest groups, supply chain partners, and employees, can use this data to make decisions June 7, 2013 PNNL-SA PNNL-SA-95363
12 Sustainability Demand N 0 Signatories More firms worldwide are aligning with Principles for Responsible Investment N 0 Signatories Assets Under Management (US$ trillion) April PNNL-SA Assets Under Management (US$ trillion) June 7, 2013 PNNL-SA
13 A Nonproliferation Pledge Acknowledge the risks of proliferation Define proliferation as a risk for the entire supply chain not just commodity manufacturers This is not a new approach: Cotton Pledge could be a model June 7, 2013 PNNL-SA
14 MEASURING SUCCESS 1. Corporate Governance Statement We supply products, services and technologies only to nations and companies from those nations that comply with international provisions in force relative to non-proliferation, IAEA safeguards and export controls. This is an absolute condition. We also comply with the governmental export policies, laws and regulations of the nations in which AREVA is located. AREVA Values Charter June 7, 2013 PNNL-SA
15 MEASURING SUCCESS 2. Participation in, or support for, an industry-wide code of conduct or pledge A Supply Chain-Wide Nonproliferation Pledge? June 7, 2013 PNNL-SA
16 MEASURING SUCCESS 3. Commitment to preferentially choosing business partners June 7, 2013 PNNL-SA
17 MEASURING SUCCESS 4. Policy on sharing suspicious trade requests Pakistan Other Countries Requirement suspected to originate in Pakistan s nuclear program Trading Company A Pakistan Manufacturer s Sales Agent Germany Manufacturer s Sales Agent Germany Manufacturer s Sales Agent France Manufacturer s Sales Agent Netherlands Image adapted from Detecting the Barrage Approach to Illicit Procurement, Institute for Science and International Security report, 2009, June 7, 2013 PNNL-SA
18 MEASURING SUCCESS 5. Participation in governmental export-control rulemaking June 7, 2013 PNNL-SA
19 MEASURING SUCCESS 6. Nonproliferation training and education for employees Sensors and Components Training Export Compliance Certification June 7, 2013 PNNL-SA
20 MEASURING SUCCESS 7. Acknowledgement of non-compliance Disclosure of Violations of nonproliferation of WMD regulations and trade sanctions Penalties, non-compliance, settlements with regulators Monetary value of any settlements or penalties June 7, 2013 PNNL-SA
21 Next Step: Outreach Supply chain participants: brokers, financiers, manufacturers Interviews Incentives Third party Metrics Validation Nonproliferation policy Corporate sustainability June 7, 2013 PNNL-SA
22 Conclusions Reputation matters Those in the proliferation supply chain have a responsibility to protect the security of their goods and services Not just reactor components, but dual-use items The corporate sustainability model may benefit nuclear suppliers and operators Reduce risk, increase competitive position Stakeholders understand a firm or agency s commitment to nonproliferation June 7, 2013 PNNL-SA
23 Contact Gretchen Hund Senior Scientist, Team Lead Global Security, Technology, and Policy Group Andrew Kurzrok Nonproliferation Scientist Global Security, Technology, and Policy Group Pacific Northwest National Laboratory Seattle, Washington, USA +1 (206) Pacific Northwest National Laboratory Washington, D.C., USA +1 (202) June 7, 2013 PNNL-SA
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