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Abstract

Proliferators continue to seek dual-use commodities that can be exploited to create weapons of mass destruction, and the private sector has a critical role to play in guarding against this threat. Corporate sustainability, which helps firms and outside stakeholders monitor the impacts of business operations, has emerged as a framework for engagement with industry on its nonproliferation responsibilities. However, the existing literature has not considered how to integrate nonproliferation into the current infrastructure of corporate sustainability, particularly into voluntary reporting standards or socially responsible investment analysis. These tools are essential market mechanisms that incentivize superior behavior on other challenges such as environmentally responsible management, respect for human rights, and fair labor practices. The authors outline the history of corporate sustainability and argue that nonproliferation should be considered a sustainability issue. They propose a nonproliferation pledge and a series of nonproliferation indicators as potential first steps that could build awareness and distinguish between firms based on how successful they are at meeting nonproliferation goals.

Keywords

corporate social responsibility corporate sustainability dual-use export control nonproliferation

In July 2012 the US Justice Department announced the indictment of Parviz Khaki, an Iranian citizen accused of conspiring to procure materials and equipment for Iran’s nuclear program. Beginning in 2008, Khaki and his accomplices allegedly contacted American dual-use commodity manufacturers, seeking products that Iran could use to improve its uranium centrifuges. Khaki allegedly stated that the products were for legitimate Chinese firms, when in reality they were destined for Iran. In two instances, items shipped to China arrived in Iran only days later (United States District Court, 2012).

The Khaki case is not unique. Instead of seeking commodities with explicitly nuclear applications, proliferators are increasingly purchasing dual-use commodities, deceiving firms and governments about their true procurement motivations, and exploiting the international financial and trade systems in the process. As the gatekeeper of international manufacturing, shipping, and banking, the private sector is often described as the first line of defense against the spread of weapons of mass destruction. However, many in industry see nonproliferation—an international security goal awash in treaties and United Nations Security Council Resolutions—as a job primarily for governments or multilateral organizations such as the International Atomic Energy Agency (IAEA), Organisation for the Prohibition of Chemical Weapons, Nuclear Suppliers Group, or Australia Group.¹

Regulation alone cannot stop all illicit procurement. An alternative approach to engaging industry on nonproliferation is to weave it into an existing framework—widely known as corporate sustainability—that the private sector uses to monitor and regulate its own behavior. Unlike government-led initiatives, corporate sustainability is the private sector’s own approach to managing the social, environmental, and economic impacts of its operations. These impacts matter because, even though they may not harm short-term profitability, they can be threats to long-term viability. Responding to these impacts can lead firms to go beyond simply complying with regulations, and to define industry-wide best practices.

This approach works because it provides rewards for improved performance. Consumers and investors stimulate competition with their wallets and portfolio allocations. Further, standardized reporting frameworks allow these stakeholders to discriminate between firms, and allow companies to make the case that their performance is better than that of their competitors. These decisions do not take place in a vacuum; judging responsibility requires detailed sets of indicators that track performance, firms dedicated to analyzing corporate disclosures, and investment platforms that judge sustainability data alongside financial data.

Several international security experts have suggested that nonproliferation should be factored into corporate ethics (Albright and Gray, 1993; Hund and Seward, 2008; Letts and Cunningham, 2009; Nuclear Power Plant Exporters, 2011a; Widl, 2012), but none have considered exactly how the existing infrastructure would need to be expanded to include nonproliferation. To be a fully effective tenet of corporate sustainability, nonproliferation will need its own set of committed companies, standards-based performance indicators, and knowledgeable investors and consumers. Without this infrastructure, dual-use manufacturers, shippers, brokers, and financiers may lack the market mechanisms that reward superior nonproliferation performance. As an initial step, firms could adopt a pledge acknowledging their commitment to nonproliferation.

Sustainability reporting: A growth industry

The past several decades have witnessed a growing recognition among many stakeholders—consumers, governments, investors, and businesses themselves—that the externalities of human activity matter. In 1987, the Bruntland Commission² published its seminal report, Our Common Future, which defined sustainable development as “development that meets the needs of the present without compromising the ability of future generations to meet their own needs” (World Commission, 1987: 43). Over time, the notion of corporate citizenship has evolved to include a range of social and governance issues, and practitioners and academics have proposed alternative terms to reflect this expansion. Table 1 includes a list of synonyms, common selection criteria, and major policy issues for those who focus on corporate ethics. Although there are some differences between the synonyms, they are sufficiently similar that “corporate sustainability” is often used to encompass the many aspects of social, environmental, and economic responsibility.

Table 1.

Defining corporate sustainability

Both supply and demand drive the market for sustainability data. On the supply side, companies track performance to support internal decision making, and publish this data to distinguish themselves from their peers. On the demand side, investors and consumers use information about corporate ethics to make investment and purchase decisions. Many elements of the corporate responsibility infrastructure facilitate this information exchange, but two of the most crucial are voluntary reporting and socially responsible investing.

Voluntary reporting, often in the form of an annual sustainability report, has emerged as the leading strategy for firms to manage their operational impacts. This report can include a message from a chief executive about the organization’s commitment, descriptions of supporting activities, and quantitative metrics on performance. The number of reports issued annually worldwide has grown from 26 in 1992 to more than 3,000 by 2008 (Lydenberg et al., 2010). In 2011, 95 percent of the world’s 250 largest companies, and 64 percent of the top 100 companies in each of 34 countries, reported on corporate citizenship (KPMG, 2011).

Prompted by the increase in corporate reporting and difficulties in making comparisons between firms, in 2000 the Global Reporting Initiative (GRI) released its first sustainability-reporting framework. GRI is now in its fourth iteration and is the de facto standard for organizations reporting on their performance. The framework includes guidelines that define how firms should measure their data, ensuring that results can be compared across firms.³ As of January 2013, GRI’s database contained data from almost 5,000 organizations.

A sustainability report is only as useful as its content, and a firm’s decision about which issues and values to select is a critical element of its approach. In general, firms report on considerations that would influence the assessments, decisions, actions, and performance of an organization or its stakeholders (AccountAbility, 2008; Global Reporting Initiative, 2011). For example, an airline’s energy usage is critically relevant, while its staff engagement may be less so (Lydenberg et al., 2010). However, the responsibility to consider impacts on stakeholders does not undercut a firm’s independence. As one accountability standard notes, “Accepting accountability to those it has an impact on (its stakeholders) does not mean that an organization has to do everything that a stakeholder requests, nor that it loses the responsibility to make its own decisions” (AccountAbility, 2008: 10).

On the demand side, an increasing number of investors are rallying behind the hypothesis that firms that look beyond the financial balance sheet may outperform their peers over both the short and long terms, and significant market evidence has corroborated this claim (Fulton et al., 2012). Known as sustainable investing, this approach relies on data from voluntary reports and other sources.

Interest in sustainable investing has led to the creation of specialized indexes, research firms, and investment advisors. One of the largest efforts is the Principles for Responsible Investment Initiative (PRI), a code of conduct launched in 2005 by the United Nations. Nearly 1,000 asset owners, investment managers, and professional service partners have signed the code, which consists of six principles that emphasize the importance of integrating corporate citizenship metrics into investment approaches.⁴ Combined, these signatories manage approximately $30 trillion worth of assets, or 20 percent of the world’s capital (Principles for Responsible Investment Initiative, 2011).

The proliferation problem

If the policy and funding priorities of governments are any guide, proliferation is a global challenge on par with other major corporate ethics issues, and it exhibits similar traits—as shown in Table 1. Effective nonproliferation requires focus from industry because proliferators solicit goods from the private sector, not from government.

Hundreds, if not thousands, of manufacturers produce tools and materials with potential WMD proliferation applications, including the 68 types of nuclear weapons dual-use commodities, the 223 types of dual-use commodities that can be used to create chemical or biological weapons, and the 79 types of dual-use commodities with applications for missile delivery.⁵ Whether or not they are aware of it, the manufacturers of these commodities are all potential targets for proliferators.

Further, dual-use commodity manufacturers, brokers, shippers, and financiers constitute an often-unintentional proliferation supply chain. Today’s proliferators can buy subcomponents in several countries, have them assembled in another location, and then ship the complete assembly through additional jurisdictions before receiving the items (Financial Action Task Force, 2008). Payments can be routed through multiple front companies and banks to hide the true buyer.

As with any illicit trade, the true volume of dual-use procurement for weapons-making purposes cannot be known. However, the following cases suggest that illicit procurement is a real and continuing threat, and illustrate the ways in which innocent companies can become involved with bad actors. This sample only includes US cases, and does not include the many voluntary self-disclosures (221 in fiscal year 2011) that exporters file with the US Commerce Department’s Bureau of Industry and Security each year (Salcido, 2012).⁶

2012

As described above, an Iranian national and a Chinese national involved in the Khaki case were indicted for allegedly attempting to obtain export-controlled items for Iran, including maraging steel, aluminum alloys, mass spectrometers, and vacuum pumps. These commodities have uranium enrichment applications.⁷

A US citizen was sentenced for attempting to export carbon fiber to Iran via the Philippines. Carbon fiber has uranium enrichment applications.⁸

2011

A major American bank was fined for numerous international finance violations, including a trade loan involving the Islamic Republic of Iran Shipping Lines sanctioned by the US Department of Treasury as a known proliferator.⁹

A Pakistani national, who was also a US permanent resident, pleaded guilty to exporting or attempting to export radiation detection devices, nuclear-grade resins for coolant water purification, calibration and switching equipment, and surface refinishing abrasives to a nuclear power plant in Pakistan. The defendant purchased these items from companies in Maryland, Massachusetts, Pennsylvania, North Dakota, Tennessee, and Texas.¹⁰

A Pennsylvania company was fined for exporting titanium alloy to China and aluminum bar to Israel. These metals are controlled for nuclear nonproliferation reasons.¹¹

An Iranian citizen was indicted for illegally exporting and attempting to export specialized steel, aluminum alloys, and welding wire for Iran’s ballistic missile program.¹²

2010

A publicly held American firm and its wholly owned Chinese subsidiary were fined after the company’s high-performance coatings were exported to Pakistan for use in a nuclear power plant.¹³

An Iranian-Canadian national was sentenced for attempting to export pressure transducers, which have uranium enrichment applications, to Iran. He purchased the pressure transducers from a company in Massachusetts and transported them to Canada.¹⁴

2009

A major international shipping firm was fined for illegal shipments to sanctioned destinations, including Iran.¹⁵

A Texas energy-services firm was fined for shipping butterfly or check valves, controlled for biological and chemical weapons reasons, on 78 occasions to Angola, Bahrain, Chad, China, India, Kazakhstan, Kuwait, Malaysia, Mexico, Oman, Pakistan, Qatar, Republic of the Congo, Saudi Arabia, Singapore, Tunisia, Turkmenistan, United Arab Emirates, Venezuela, and Vietnam.¹⁶

Participation in proliferation activities can bring costs to firms as well as to their investors and customers, including financial damages, loss of reputation, increased regulation, and externalized social and potentially environmental costs. For those who knowingly take part in proliferation activities, most jurisdictions have heavy penalties for export control noncompliance, including fines, lost export privileges, and imprisonment. In the United States, administrative penalties can exceed $250,000 per violation, and criminal penalties can reach $1 million and 20 years imprisonment per violation.

Often the reputation costs of noncompliance are as high as the legal penalties. Oerlikon Leybold Vacuum, for example, supplied vacuum pumps to Iraq’s nuclear weapons program in the 1980s (Albright, 2010). When caught, the company was nearly barred from the US market. Since then, it has become a corporate leader in nonproliferation. By its own accounting, Leybold has turned down more than 25 million euros in potential sales because of proliferation concerns. However, the stigma of past violations can remain strong. As recently as 2011 the company’s CEO referred to the firm’s past mistakes as “Jurassic business” (Widl, 2011).

The impact of one company’s error can have a ripple effect: Other firms within that industry may fall under greater scrutiny and regulation as well. For example, the civilian nuclear power sector worldwide suffered after the accidents at Chernobyl and Three Mile Island. In response, over the next three decades, “safety first” became an organizing principle for nuclear operations.

The nuclear safety experience may offer lessons for nonproliferation as well. In the aftermath of a severe proliferation event, such as a first nuclear test by a breakout proliferator, sectors within the proliferation supply chain could become targets for increased regulation. By including nonproliferation as an explicit goal, innocent companies could potentially avoid becoming scapegoats.

The burdens of proliferation borne by the public are as significant as the costs to firms, if not more so. Tracking and reducing the spread of dual-use commodities require significant expenditures for diplomacy, intelligence, defense, and international verification. These costs are a nontrivial tax burden, but the cost of a nuclear attack would be far greater, both in human suffering and economic disruption. A 2003 study (Abt Associates, 2003) calculated that the economic impact of a Hiroshima-scale 10- to 20-kiloton nuclear terrorist attack would include a trade disruption of $100 to $200 billion and property losses of $50 to $500 billion. The long-term effects of increased security and regulation were judged to be “substantially greater.”

Incorporating nonproliferation

Nonproliferation can be integrated into corporate citizenship to varying degrees. A declaration by businesses is a first step. Beyond that, weaving nonproliferation into standards such as the Global Reporting Initiative would move nonproliferation reporting into the mainstream of sustainability considerations. Because a core tenet of corporate responsibility is stakeholder involvement, firms within the proliferation supply chain should decide exactly how to incorporate nonproliferation into existing frameworks. Among the possible options:

Pledging nonproliferation

An obvious but essential data point for stakeholders is simply the knowledge that a firm values nonproliferation. To this end, the development and acceptance of a “nonproliferation pledge” could help firms within the proliferation supply chain communicate their commitment to stopping the illicit spread of dual-use commodities. Such pledges are commonly used by industries to acknowledge that an issue exists, and that they are serious about addressing it. Many apparel manufacturers and retail stores, for example, have signed a “cotton pledge” not to source materials from Uzbekistan until the Uzbek government ends forced child labor in cotton production. A nonproliferation pledge would be a similarly strong statement from firms that are committed to breaking the proliferation supply chain.

There is a precedent for a nonproliferation pledge: Principle 5 of the recent Nuclear Power Plant Exporters’ Principles of Conduct calls on firms to ensure that their sales are exclusively for peaceful uses, but this commitment is limited to reactor manufacturers (Nuclear Power Plant Exporters, 2011b). A stand-alone nonproliferation pledge could be adopted by a broader range of companies: dual-use manufacturers, shippers, brokers, financiers, and others exposed to illicit procurement.

Reporting on nonproliferation performance

Beyond a statement of adherence to nonproliferation principles, nonproliferation performance indicators could help monitor execution and provide a basis for preferred investment. Some performance indicators are qualitative and others are quantitative. Some can be applied generally, while others are most useful as an element of a sector-specific reporting framework. These options include:

1. Corporate governance statement

Many firms have a corporate code of ethics that defines the company’s values. These documents are often a new hire’s first introduction to the company’s culture. Senior management could communicate its commitment to nonproliferation by including it among the company’s values. For example, the Values Charter of AREVA, a French nuclear conglomerate, states:

We supply products, services, and technologies only to nations and companies from those nations that comply with international provisions in force relative to nonproliferation, 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, 2012)

2. Participation in, or support for, an industry-wide code of conduct or pledge

In addition to the stand-alone pledge described above, an industry-wide code of conduct or nonproliferation pledge could serve as an indicator within a broader set of metrics. This indicator would underscore corporate commitment while at the same time building support for an industry-wide document. Firms that participate in other codes of conduct, such as the 2011 Nuclear Power Plant Exporters’ Principles of Conduct, could also note their participation through this metric.

3. Commitment to preferentially choosing business partners

Proliferation requires a supply chain. By preferentially choosing suppliers, contractors, and other business partners that also make a demonstrable effort not to proliferate, companies use market forces to encourage industries to meet the same standards as themselves. This metric would identify firms that have a corporate policy on incentivizing nonproliferation throughout their supply chains.

4. Policy on sharing suspicious trade requests

Many firms fulfill their nonproliferation commitments by refusing to fill suspicious orders. However, this often means the company simply discards the request, destroying a potential source of intelligence. Forwarding this information to government analysts could support their counterproliferation investigations. Going one step further, an industry could create a third party to manage a central database of all rejected inquiries. Because proliferators have been known to request the same item from multiple firms, sharing denials through a single point of contact could help all firms avoid illicit trade.

5. Participation in governmental export control rulemaking

The US government regularly solicits feedback from industry on changes to export control regulations, often through notices of inquiry published in the Federal Register. Similarly, the European Commission solicits industry feedback on its dual-use technology control regulations. This performance indicator would describe the extent to which a company participates in activities such as responding to governmental requests for comment.

6. Nonproliferation training and education for employees

Skills deteriorate over time if not used, and many professions require continuing education. This performance indicator would identify a company’s commitment to sustaining an awareness of nonproliferation throughout the corporation. Training topics could include export control regulations, possible red flags, and case studies of noncompliance. To ensure compliance, this metric could be computed on an annual basis and could also disclose what percentage of employees successfully completed the requirement.

7. Acknowledgment of noncompliance

This metric could be patterned after similar Global Reporting Initiative performance indicators. The organization explains the importance of this metric as:

The level of noncompliance within the organization helps to indicate the ability of management to ensure that operations conform to certain performance parameters. From an economic perspective, ensuring compliance helps to reduce financial risks that occur either directly through fines or indirectly through impacts on reputation. The strength of an organization’s compliance record can also affect its ability to expand operations or gain permits. (Global Reporting Initiative, 2011: 165)

Under this indicator, companies would list all penalties, voluntary self-disclosures, or settlements with regulators that stem from violations of nonproliferation regulations or trade sanctions prompted by foreign WMD activity. Disclosures should note the monetary value of all penalties and include settlements without an admission of guilt.

A sustainable future

Few, if any, firms within the proliferation supply chain see themselves as in the “weapons business,” but the risks posed by proliferation can impact both international security and their bottom lines. Corporate citizenship provides firms with a results-oriented approach to nonproliferation.

In particular, incorporating nonproliferation into sustainability performance indicators would help responsible investors move beyond today’s inadequate approach to assessing nuclear threats. Some investment firms currently use “negative screens” to weed out investments in companies that support the nuclear energy or defense sectors. Simply avoiding business with such firms does not address illicit procurement because they rarely manufacture the parts that today’s proliferators seek; proliferators have moved up the supply chain to dual-use commodities. While investors may choose to retain these negative screens on other grounds, they should not be relied upon to guarantee nonproliferation. Investors need more data from a wider supply chain.

Integrating nonproliferation into corporate ethics infrastructure will not be a singular event, nor will it be the complete solution to a public–private partnership on illicit procurement. As companies, proliferation patterns, and the concept of sustainable performance all evolve, the nature of the relationship among them will change. Firms, governments, investors, and consumers will need to adapt to these changes to remain relevant. Further, even under perfect circumstances, the value of nonproliferation as an element of sustainability will depend on the number of firms within the proliferation supply chain that value sustainability itself. Some firms, particularly small and medium-sized enterprises, may have little or no capacity to address these issues. Engaging these firms will likely require large companies to use their own purchasing power—and commitment to corporate responsibility—to encourage similar responsibility throughout their supply chains.

In the long run, the spread of weapons of mass destruction will be governed by the demand for the weapons’ perceived benefits. The technical know-how and raw natural resources needed to make weapons ultimately cannot be controlled; what can be controlled, however, are commodities that could be misused to parlay knowledge and materials into bombs. Many of the manufacturers, shippers, brokers, and financiers of dual-use commodities already responsibly manage and report on other global threats. Expanding these efforts to include nonproliferation is good business and good citizenship, the keys to corporate sustainability.

Footnotes

Funding

This work was supported under Prime Contract Number DE-AC05-76RL01830 for the US Department of Energy.

Notes

Author biographies

Andrew Kurzrok is a nonproliferation scientist at the Pacific Northwest National Laboratory in Seattle. He focuses on export control, international safeguards, and multilateral nuclear policy.

Gretchen Hund is a senior scientist at the Pacific Northwest National Laboratory in Seattle. She has more than 25 years of experience addressing topics that combine science, technology, and public policy issues. From 1985 to 1990, she was a project manager and senior analyst at the US Congressional Office of Technology Assessment.

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