Global Citizenship
Social Impact of the GPU2012 Citizenship ReportNVIDIA Foundation
 
 
 
 

GRI Index

NVIDIA has applied the internationally recognized Global Reporting Initiative (GRI) G3 Sustainability Reporting Guidelines in producing the 2012 Citizenship Report. We are self-declaring a "B+" Application Level. The index below provides a full list of the GRI disclosures and indicators. As per the GRI Guidelines, we indicate whether we answered the indicator, if the answer is full or partial, and the relevant webpage where you can find information for each disclosure we responded to. Please follow these links for more information on the GRI guidelines and the GRI application levels.

GRI Guidelines Key: Completely Addressed Completely Addressed Partially Addressed Partially Addressed Not Addressed Not Addressed

Strategy and Analysis
  Section Guideline Status  
  1.1 Statement from the most senior decision-maker of the organization.
CEO Letter,
Annual Review CEO Letter, pp.1-3
Completely Addressed  
 
  1.2 Description of key impacts, risks, and opportunities.
Products and Services
Priority Issues
Workforce
Environment
Completely Addressed  
 

Organizational Profile
  Section Guideline Status  
  2.1 Name of the organization.
Economic Impact
Completely Addressed  
 
  2.2 Primary brands, products, and/or services.
Our Company
Products and Services
10-K pp.4, 8
Completely Addressed  
 
  2.3 Operational structure of the organization, including main divisions, operating companies, subsidiaries, and joint ventures.
10-K pp.4-5
Completely Addressed  
 
  2.4 Location of organization's headquarters.
Our Company,
Our Locations
Completely Addressed  
 
  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.
Our Company,
Our Locations
Completely Addressed  
 
  2.6 Nature of ownership and legal form.
Economic Impact
Completely Addressed  
 
  2.7 Markets served (including geographic breakdown, sectors served, and types of customers/beneficiaries).
Products and Services
Completely Addressed  
 
  2.8 Scale of the reporting organization.
Economic Impact
Workforce
Completely Addressed  
 
  2.9 Significant changes during the reporting period regarding size, structure, or ownership.
10-K pp.79-82; 83-84; 99
Completely Addressed  
 
  2.10 Awards received in the reporting period.
Workplace
Environment
Product Design
Completely Addressed  
 

Report Parameters
  Section Guideline Status  
  3.1 Reporting period (e.g., fiscal/calendar year) for information provided.
Introduction
Completely Addressed  
 
  3.2 Date of most recent previous report (if any).
About this Report
Completely Addressed  
 
  3.3 Reporting cycle (annual, biennial, etc.)
About this Report
Completely Addressed  
 
  3.4 Contact point for questions regarding the report or its contents.
About this Report
Completely Addressed  
 
  3.5 Process for defining report content.
About this Report
Priority Issues
Completely Addressed  
 
  3.6 Boundary of the report (e.g., countries, divisions, subsidiaries, leased facilities, joint ventures, suppliers). See GRI Boundary Protocol for further guidance.
About this Report
Completely Addressed  
 
  3.7 State any specific limitations on the scope or boundary of the report (see completeness principle for explanation of scope).
About this Report
Assurance statement
Completely Addressed  
 
  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.
About this Report
Completely Addressed  
 
  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.
Talent Development
Assurance statement
Completely Addressed  
 
  3.10 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).
There have been no restatements.
Completely Addressed  
 
  3.11 Significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report.
There have been no significant changes.
Completely Addressed  
 
  3.12 Table identifying the location of the Standard Disclosures in the report.
This GRI Index
Completely Addressed  
 
  3.13 Policy and current practice with regard to seeking external assurance for the report.
Emissions Assurance
Completely Addressed  
 

Governance, Commitments, and Engagement
  Section Guideline Status  
  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.
Governance
Annual Review, pp.23-25
Completely Addressed  
 
  4.2 Indicate whether the Chair of the highest governance body is also an executive officer.
Governance
Completely Addressed  
 
  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.
Governance
Completely Addressed  
 
  4.4 Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body.
Governance
Annual Review pp. 6, 28
Completely Addressed  
 
  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).
Annual Review pp. 6, 41-49
Completely Addressed  
 
  4.6 Processes in place for the highest governance body to ensure conflicts of interest are avoided.
Governance
Annual Review p. 27
Completely Addressed  
 
  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.
Annual Review pp. 28, 7
Completely Addressed  
 
  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.
Governance
Company Policies
Who We Are and What We Do
Global Citizenship Directive
Corporate Culture
Completely Addressed  
 
  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.
Annual Review pp. 26-28
Completely Addressed  
 
  4.10 Processes for evaluating the highest governance body's own performance, particularly with respect to economic, environmental, and social performance.
Annual Review pp. 15, 16 and 23
Completely Addressed  
 
  4.11 Explanation of whether and how the precautionary approach or principle is addressed by the organization.
Governance
Completely Addressed  
 
  4.12 Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organization subscribes or endorses.
Supply Chain
Talent Development
Key Environmental Metrics
Completely Addressed  
 
  4.13 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.
Stakeholder Engagement
Supply Chain
Completely Addressed  
 
  4.14 List of stakeholder groups engaged by the organization.
Stakeholder Engagement
Completely Addressed  
 
  4.15 Basis for identification and selection of stakeholders with whom to engage.
Stakeholder Engagement
Completely Addressed  
 
  4.16 Approaches to stakeholder engagement, including frequency of engagement by type and by stakeholder group.
Stakeholder Engagement
Completely Addressed  
 
  4.17 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.
Priority Issues
Talent Development
Completely Addressed  
 

DISCLOSURES ON MANAGEMENT APPROACH (DMAs)
Disclosure on Management Approach EC
  Section Guideline Status  
  DMA EC1 Economic performance
Annual Review CEO Letter, pp.1-3
10-K pp.3-8
Completely Addressed  
 
  DMA EC2 Market presence Not Addressed  
 
  DMA EC3 Indirect economic impacts
EC8; Compute the Cure
Completely Addressed  
 

Disclosure on Management Approach EN
  Section Guideline Status  
  DMA EN1 Materials
Product Design
Supply Chain
Partially Addressed  
 
  DMA EN2 Energy
Environment
Environment Goals and Progress
Key Environmental Metrics
Supply Chain
Campus Operations
Completely Addressed  
 
  DMA EN3 Water
Supply Chain
Partially Addressed  
 
  DMA EN4 Biodiversity Not Addressed  
 
  DMA EN5 Emissions, effluents and waste
Environment
Environment Goals and Progress
Key Environmental Metrics
Campus Operations
Completely Addressed  
 
  DMA EN6 Products and services
Product Design
Partially Addressed  
 
  DMA EN7 Compliance
Environment
Environment Goals and Progress
Key Environmental Metrics
Completely Addressed  
 
  DMA EN8 Transport
Product Design
Partially Addressed  
 
  DMA EN9 Overall
Product Design
Partially Addressed  
 

Disclosure on Management Approach LA
  Section Guideline Status  
  DMA LA1 Employment
Workforce
Workforce Goals and Targets
Partially Addressed  
 
  DMA LA2 Labor/management relations
LA4
Talent Development
Partially Addressed  
 
  DMA LA3 Occupational health and safety
Safety and Health.
Partially Addressed  
 
  DMA LA4 Training and education
Talent Development
Workforce Goals and Progress
Completely Addressed  
 
  DMA LA5 Diversity and equal opportunity
Talent Development
Workforce Goals and Progress
University Partnerships
Completely Addressed  
 

Disclosure on Management Approach HR
  Section Guideline Status  
  DMA HR1 Investment and procurement practices
Safety and Health
Partially Addressed  
 
  DMA HR2 Non-discrimination
Talent Development
Partially Addressed  
 
  DMA HR3 Freedom of association and collective bargaining
Talent Development
Environmental Goals and Progress
Partially Addressed  
 
  DMA HR4 Child labor
HR6
Completely Addressed  
 
  DMA HR5 Forced and compulsory labor
HR7
Completely Addressed  
 
  DMA HR6 Security practices Not Addressed  
 
  DMA HR7 Indigenous rights Not Addressed  
 

Disclosure on Management Approach SO
  Section Guideline Status  
  DMA SO1 Community Not Addressed  
 
  DMA SO2 Corruption
SO2, SO3,
Governance
Completely Addressed  
 
  DMA SO3 Public policy Not Addressed  
 
  DMA SO4 Anti-competitive behavior
SO7
Worldwide Code of Conduct
Completely Addressed  
 
  DMA SO5 Compliance
SO8
Worldwide Code of Conduct
Completely Addressed  
 

Disclosure on Management Approach PR
  Section Guideline Status  
  DMA PR1 Customer health and safety
Product Design
Partially Addressed  
 
  DMA PR1 Product and service labelling
PR5
Partially Addressed  
 
  DMA PR1 Marketing communications Not Addressed  
 
  DMA PR1 Customer privacy Not Addressed  
 
  DMA PR1 Compliance
PR9
Completely Addressed  
 

Economic
  Section Guideline Status  
  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.
Economic Impact
Completely Addressed  
 
  EC2 Financial implications and other risks and opportunities for the organization's activities due to climate change.
CDP Response pp.2-6
Completely Addressed  
 
  EC3 Coverage of the organization's defined benefit plan obligations.
Not Addressed  
 
  EC4 Significant financial assistance received from government.
In August 2010, NVIDIA received a $8.29 Million Contract from DARPA to develop high-performance GPU computing systems. The four-year research contract, awarded under DARPA's Ubiquitous High Performance Computing (UHPC) program, covers work to develop GPU technologies required to build the new class of exascale supercomputers, which will be 1,000-times more powerful than today's fastest supercomputers. The US government is not a registered shareholder of NVIDIA Corporation.
Partially Addressed  
 
  EC5 Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation. Not Addressed  
 
  EC6 Policy, practices, and proportion of spending on locally-based suppliers at significant locations of operation. Not Addressed  
 
  EC7 Procedures for local hiring and proportion of senior management hired from the local community at significant locations of operation.
Talent Development
Partially Addressed  
 
  EC8 Development and impact of infrastructure investments and services provided primarily for public benefit through commercial, in-kind, or pro bono engagement.
We executed a 'Development Agreement' with the City in 2009. As part of this agreement we put up a $5M Letter of Credit, against which the City can draw down to help fund infrastructure projects in the City of Santa Clara. This investment was made based upon traffic impact studies required under environmental impact and traffic planning regulations. Our hope is that this investment in the community infrastructure near our campus will improve traffic flow, decrease employees' commuting time, and improve the safety and quality of life of residents. See also Compute the Cure.
Completely Addressed  
 
  EC9 Understanding and describing significant indirect economic impacts, including the extent of impacts. Not Addressed  
 

Environmental
  Section Guideline Status  
  EN1 Materials used by weight or volume. Not Addressed  
 
  EN2 Percentage of materials used that are recycled input materials. Not Addressed  
 
  EN3 Direct energy consumption by primary energy source.
Key Environmental Metrics
Completely Addressed  
 
  EN4 Indirect energy consumption by primary source.
Key Environmental Metrics
Partially Addressed  
 
  EN5 Energy saved due to conservation and efficiency improvements.
Campus Operations
Partially Addressed  
 
  EN6 Initiatives to provide energy-efficient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives.
Product Design
Partially Addressed  
 
  EN7 Initiatives to reduce indirect energy consumption and reductions achieved.
Campus Operations
Partially Addressed  
 
  EN8 Total water withdrawal by source.
Key Environmental Metrics
Partially Addressed  
 
  EN9 Water sources significantly affected by withdrawal of water. Not Addressed  
 
  EN10 Percentage and total volume of water recycled and reused.
Key Environmental Metrics
Completely Addressed  
 
  EN11 Location and size of land owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas.
We do not own property located near land with biodiversity value.
Completely Addressed  
 
  EN12 Description of significant impacts of activities, products, and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas.
We do not own property located near land with biodiversity value.
Completely Addressed  
 
  EN13 Habitats protected or restored.
We did not protect or restore any habits.
Completely Addressed  
 
  EN14 Strategies, current actions, and future plans for managing impacts on biodiversity. Not Addressed  
 
  EN15 Number of IUCN Red List species and national conservation list species with habitats in areas affected by operations, by level of extinction risk. Not Addressed  
 
  EN16 Total direct and indirect greenhouse gas emissions by weight.
Environment
Emissions Assurance
Completely Addressed  
 
  EN17 Other relevant indirect greenhouse gas emissions by weight.
Key Environmental Metrics
Completely Addressed  
 
  EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved.
Campus Operations
Completely Addressed  
 
  EN19 Emissions of ozone-depleting substances by weight.
Our Ozone Depleting Substances are reported on this page.
Completely Addressed  
 
  EN20 NOx, SOx, and other significant air emissions by type and weight.
Key Environmental Metrics
Partially Addressed  
 
  EN21 Total water discharge by quality and destination.
Key Environmental Metrics
Completely Addressed  
 
  EN22 Total weight of waste by type and disposal method.
Key Environmental Metrics
Partially Addressed  
 
  EN23 Total number and volume of significant spills.
There have been no significant spills.
Partially Addressed  
 
  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.
1.2 Total weight (tonnes) of hazardous waste transported;
0 Total weight of imported hazardous waste;
0 Total weight of exported hazardous waste;
1.2 Total weight (tonnes) of treated hazardous waste;
Global hazardous waste generation (treated) is 1.2 tonnes.
Completely Addressed  
 
  EN25 Identity, size, protected status, and biodiversity value of water bodies and related habitats significantly affected by the reporting organization's discharges of water and runoff.
We had zero discharges, and therefore no affects.
Completely Addressed  
 
  EN26 Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation.
Product Design
Supply Chain
In addition, see NVIDIA's white paper outlining the energy efficiency of its latest Kepler architecture for chips: http://www.geforce.com/whats-new/articles/introducing-the-geforce-gtx-680-gpu/
Partially Addressed  
 
  EN27 Percentage of products sold and their packaging materials that are reclaimed by category. Not Addressed  
 
  EN28 Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with environmental laws and regulations.
Key Environmental Metrics
We consider significant fines those that are required to be disclosed in the company's SEC filings. There were no fines in 2011 that fell into this category. We also were not subject to any non-monetary sanctions for non-compliance with environmental laws and regulations.
Completely Addressed  
 
  EN29 Significant environmental impacts of transporting products and other goods and materials used for the organization's operations, and transporting members of the workforce.
Product Design
Partially Addressed  
 
  EN30 Total environmental protection expenditures and investments by type.
Key Environmental Metrics
Completely Addressed  
 

Social: Labor Practices and Decent Work
  Section Guideline Status  
  LA1 Total workforce by employment type, employment contract, and region.
Workforce
Completely Addressed  
 
  LA2 Total number and rate of employee turnover by age group, gender, and region.
Talent Development
Partially Addressed  
 
  LA3 Benefits provided to full-time employees that are not provided to temporary or part-time employees, by major operations.
US employees are eligible to enroll in NVIDIA's health and welfare programs if they are regular, full-time or part-time employees normally scheduled to work 20 hours or more per week. PT employees working fewer than 20 hours/week are not eligible. See also Talent Development.
Completely Addressed  
 
  LA4 Percentage of employees covered by collective bargaining agreements.
None of our employees is covered by collective bargaining agreements.
Completely Addressed  
 
  LA5 Minimum notice period(s) regarding significant operational changes, including whether it is specified in collective agreements. Not Addressed  
 
  LA6 Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programs. Not Addressed  
 
  LA7 Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region. Not Addressed  
 
  LA8 Education, training, counseling, prevention, and risk-control programs in place to assist workforce members, their families, or community members regarding serious diseases.
Talent Development
Safety and Health
Partially Addressed  
 
  LA9 Health and safety topics covered in formal agreements with trade unions. Not Addressed  
 
  LA10 Average hours of training per year per employee by employee category. Not Addressed  
 
  LA11 Programs for skills management and lifelong learning that support the continued employability of employees and assist them in managing career endings.
Talent Development
Partially Addressed  
 
  LA12 Percentage of employees receiving regular performance and career development reviews. Not Addressed  
 
  LA13 Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership, and other indicators of diversity.
Governance
Annual Review p. 23
Talent Development
Completely Addressed  
 
  LA14 Ratio of basic salary of men to women by employee category. Not Addressed  
 

Social: Human Rights
  Section Guideline Status  
  HR1 Percentage and total number of significant investment agreements that include human rights clauses or that have undergone human rights screening. Not Addressed  
 
  HR2 Percentage of significant suppliers and contractors that have undergone screening on human rights and actions taken.
Safety and Health
Partially Addressed  
 
  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. Not Addressed  
 
  HR4 Total number of incidents of discrimination and actions taken. Not Addressed  
 
  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.
Talent Development
Partially Addressed  
 
  HR6 Operations identified as having significant risk for incidents of child labor, and measures taken to contribute to the elimination of child labor.
In 2010, the State of California enacted into law the California Transparency in Supply Chain Act, which has provisions for child labor. Even though NVIDIA is not subject to this Act, we plan to voluntarily comply and have notified our Customers of our intent to comply. As a first step for compliance, we plan to put into place a process to ensure that we can address the requirements of the Act. As an EICC member, we are evaluating the use of the Validated Audit Process (VAP) or VAP-lite as the audit vehicle to confirm that our key suppliers do not engaged in child labor practices. We have also drafted a certificate of confirmation that we plan to send to each of our suppliers to confirm understanding and compliance with the Act. Within NVIDIA, we have identified no operations as having significant risk for incidents of child labor. See also, Safety and Health
Supply Chain
Completely Addressed  
 
  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.
In 2010, the State of California enacted into law the California Transparency in Supply Chain Act, which has provisions for forced labor. Even though NVIDIA is not subject to this Act, we plan to voluntarily comply and have notified our Customers of our intent to comply. As a first step for compliance, we plan to put into place a process to ensure that we can address the requirements of the Act. As an EICC member, we are evaluating the use of the Validated Audit Process (VAP) or VAP-lite as the audit vehicle to confirm that our key suppliers do not engaged in forced labor practices. We have also drafted a certificate of confirmation that we plan to send to each of our suppliers to confirm understanding and compliance with the Act. Within NVIDIA, we have identified no operations as having significant risk for incidents of forced or compulsory labor. See also, Safety and Health
Supply Chain
Completely Addressed  
 
  HR8 Percentage of security personnel trained in the organization's policies or procedures concerning aspects of human rights that are relevant to operations. Not Addressed  
 
  HR9 Total number of incidents of violations involving rights of indigenous people and actions taken. Not Addressed  
 

Social: Society
  Section Guideline Status  
  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. Not Addressed  
 
  SO2 Percentage and total number of business units analyzed for risks related to corruption.
Internal audit did a fraud/corruption analysis in 2011, entity-wide, to identify potential fraud schemes. We have analyzed 100% of our operations, which includes 8 business areas.
Completely Addressed  
 
  SO3 Percentage of employees trained in organization's anti-corruption policies and procedures.
In 2010 we rolled out an online training which includes corruption and fraud; enhanced training will be rolled out in 2012. Training related to corruption and fraud was incorporated into a Code of Conduct training we rolled out in 2010; our latest data shows that 65% of global employees have completed this training (our goal is 100%). See also Governance.
Completely Addressed  
 
  SO4 Actions taken in response to incidents of corruption. Not Addressed  
 
  SO5 Public policy positions and participation in public policy development and lobbying. Not Addressed  
 
  SO6 Total value of financial and in-kind contributions to political parties, politicians, and related institutions by country. Not Addressed  
 
  SO7 Total number of legal actions for anti-competitive behavior, anti-trust, and monopoly practices and their outcomes.
There were no actions for anti-competitive behavior initiated against NVIDIA in 2011.
Completely Addressed  
 
  SO8 Monetary value of significant fines and total number of non-monetary sanctions for non-compliance with laws and regulations.
We consider significant fines those that are required to be disclosed in the company's SEC filings. We were not subject to any fines or non-monetary sanctions in 2011 for non-compliance with laws and regulations.
Completely Addressed  
 

Social: Product Responsibility
  Section Guideline Status  
  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.
Product Design
Partially Addressed  
 
  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. Not Addressed  
 
  PR3 Type of product and service information required by procedures, and percentage of significant products and services subject to such information requirements. Not Addressed  
 
  PR4 Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labeling, by type of outcomes. Not Addressed  
 
  PR5 Practices related to customer satisfaction, including results of surveys measuring customer satisfaction.
NVIDIA Customer Care group has implemented customer satisfaction surveys since 2006. This survey is intended to provide data directly from our customers regarding our support capabilities with the intent of using the data to drive continual improvements.Customer Satisfaction is the objective from which NVIDIA's Customer Care Key Performance Indicators are derived. NVIDIA's customer support web site, http://www.nvidia.com/page/support.html, offers support on a wide variety of topics, a robust customer forum and live help. NVIDIA customer care also closely monitors social media tools such as the NVIDIA blog, Facebook and Twitter accounts, to respond to customer support questions and concerns.
Partially Addressed  
 
  PR6 Programs for adherence to laws, standards, and voluntary codes related to marketing communications, including advertising, promotion, and sponsorship. Not Addressed  
 
  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. Not Addressed  
 
  PR8 Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data. Not Addressed  
 
  PR9 Monetary value of significant fines for non-compliance with laws and regulations concerning the provision and use of products and services.
We consider significant fines those that are required to be disclosed in the company's SEC filings. We were not subject to any fines in 2011 for non-compliance with laws and regulations concerning the provision and use of products and services.
Completely Addressed