ELDGuide2011 by zhangyun


									   A GUIDE TO
                Liability in

   FOREWORD                                                                 2 | Introduction
                                                                            The ELD brings consequences

          ENVIRONMENTAL LIABILITY IS                                        4 | Germany
          nothing new in Europe. Yet                                        A two-tier system makes life
          European risk managers still                                      difficult for risk managers
          aren’t seeing the need to buy a
          standalone environmental                                          6 | France
          insurance product. Many are                                       The Bouches-du-Rhône disaster
          happy to seek out extensions in                                   illustrated the cost of pollution
          their general liability policies to cover risks introduced by
          the Environmental Liability Directive (ELD).                      8 | United Kingdom
               A number of environmental disasters have occurred            Firms are still burying their
          in Europe since the ELD passed into law. France’s                 head in the sand over the ELD
          Bouches-du-Rhône oil spill received a great deal of media
          attention, yet the take-up of environmental insurance             10 | Spain & Portugal
          products remains low. And in the case of the Hungarian            Cover is mandatory but firms
          toxic spill, the government fears cracking down on the            still lack awareness
          company involved for political and economic reasons.
          Neither incident has provided particularly accurate data for      12 | Eastern Europe
          what constitutes environmental liability or shown how             The fall-out from the toxic spill
          regulators will approach the subject in a post-ELD world.
               So, as risk managers mull the consequences of a              14 | Scandinavia
          major incident, insurance could start to look like the right      Why Scania won’t buy ELD cover
          option. But the decision might not be le in their hands
          for much longer. The European Commission is considering           16 | Resolving a claim
          introducing a Europe-wide mandatory financial protection           The environment’s true value
          scheme. Companies may have to buy insurance or find
          another way of reserving cash to pay for the clean-up if          18 | Buying the right cover
          they cause damage to the environment.                             Assessing the impact of the ELD
                                Nathan Skinner is editor of StrategicRISK
                                                                            20 | Conclusion
                                                                            More data is needed before ELD
                                                                            take-up will increase

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                                                                                              Strategic RISK   1

                                                                    operators are required to take
Do you know                                                         preventative measures in the event of an
                                                                    imminent threat of environmental
the consequences of                                                 damage. This proactive approach
                                                                    contrasts with established environmental
environmental liability?                                            law, which is mainly concerned with
                                                                    repairing the damage a er the event.

Focusing on the financial repercussions of                           Financial drivers
                                                                    There is still much uncertainty
pollution, the Environmental Liability                              surrounding the operation and
Directive brings much-needed clarity                                enforcement of the ELD, particularly in
                                                                    terms of financial penalties for polluters.
                                                                    This is understandable given how

                     W         ITHOUT QUESTION, THE
                               Environmental Liability Directive
                     (ELD) is a significant development in
                                                                    wide-reaching it is geographically and
                                                                    with respect to the liabilities created, so
                                                                    only time will tell as the law is allowed to
                     environmental law, but we must be              ‘bed in’ across the EU.
                     mindful not to focus solely on this most            One key driver behind enforcement
                     recent legislation and ignore existing law,    will be the resources available to the
                     which is well regulated in many                regulators. Unfortunately, tough economic
                     territories. These laws still exist and will   times see public bodies reducing staff
                     still be enforced alongside the ELD, not       numbers, which will only weaken their
                     replaced by it. In some EU member states,      ability to enforce new regulations.
                     however, the position is very different, as         The economic climate may also be
                     less well-developed environmental law          responsible for government reluctance in
                     means the ELD has meant a more                 enforcing environmental regulations too
                     fundamental change.                            strictly. The need to help industry out of
                           What the ELD does do well is focus       recession means a heavy-handed
                     far more attention on the consequences         approach to enforcement may not be the
                     of environmental damage, particularly          right way to go at this time.
                     with respect to natural habitats and                Regardless of enforcement activity,
                     protected species, which we may call           changes in legislation are a positive
                     ‘biodiversity’. Indeed, the introduction of    driver in companies’ growing awareness
                     complementary and compensatory                 of their environmental responsibilities,
                     remediation costs is testament to this         which is coupled with an increased focus
                     core focus, and demonstrates how the           on corporate responsibility across the
                     financial consequences of environmental         board. Reputational risk is certainly a big
                     damage for the polluter will be more           part of this as customers, shareholders,
                     severe under the new regime. The               investors and other stakeholders will
                     introduction of strict liability is another    increasingly look at environmental
                     important development, replacing the           performance when making decisions.
                     need to prove fault or negligence for               While companies may be more aware
                     many ‘regulated’ industry sectors.             of environmental risk, recognition of the
                           The ELD also looks closely at            consequences – despite the legislative
                     preventing incidents in the first place, as     drivers – is questionable. Many will

 2   StrategicRISK
associate such risks with large-scale
pollution events, such as that which              SUMMARY
occurred in the Gulf of Mexico last year.         The Environmental Liability Directive
     This focus on severity means
businesses, regardless of type and size,          •    The ELD focuses on the consequences of environmental
overlook their own environmental                       damage and recognises the need to expand existing laws.
exposures, plus it must be remembered             •    Financial provision for environmental damage is a rapidly
that financial consequences for each                    developing requirement in the EU, and companies should
company are relative. Indeed, the costs                protect their business regardless of legal requirements.
of remedying environmental damage                 •    Demand for environmental insurance has risen in line with
may easily be absorbed by one                          risk awareness.
organisation, but could threaten                  •    Economic conditions mean many organisations cannot
the solvency of another.                               afford to assess environmental risks or take out insurance
                                                       – but they cannot afford the uninsured losses either.
Covering yourself
One very important development
championed by the ELD in particular is          other EU territories, but of late has
the concept of financial provision for           focused on ‘operational’ environmental
environmental damage. While this                risks: those that companies face as a
initiative is still in its infancy across the   result of their ongoing business activities.
EU and has without doubt been slowed            The goal here is that this type of
by the current economic downturn, it is a       insurance be considered in the same way
significant change and presents good             as other lines, like public liability or
opportunities for the insurance industry.       property.
Insurance is seen by many as the most                There is room for development, but
obvious and arguably efficient solution to      specialist insurers in this sector have
satisfy financial provision requirements.        made significant strides in making this
     Transferring the financial                  type of insurance accessible and
consequences of environmental risks to          affordable for all organisations,
the insurance market should be a key            irrespective of size or industry sector.
consideration for companies whether             Certainly, environmental risk insurance
legislation encourages it or not. While         is not exclusively for large multinational
many organisations are unlikely to act          corporations; a wide range of entities
unless forced to by legal or contractual        from small family-run firms to global
requirements, it is evident that as             organisations have adopted this level of
awareness of environmental risks has            risk management.
developed, so too has demand for                     Current economic conditions are
environmental insurance solutions.              making it difficult for many to assess
     Companies that appreciate the              environmental risks or indeed purchase
importance of such risks and the need to        adaquate insurance protection, but
manage them strategically also recognise        companies must ask whether they are
that environmental insurance can be an          able to afford the consequences of
efficient and effective means to support        uninsured environmental events. SR
this strategy.
     The environmental insurance market         Wayne Harrington is UK and Ireland
is well established in the UK and many          manager of environmental risk at ACE

                                                                                                  Strategic RISK    3

In this environmental                                                    KEY ADDITIONAL
                                                                         LIABILITIES FROM THE ELD
state, the polluter
always pays                                                              •    Operators have to report any
                                                                              pollution incident – it is a
                                                                              criminal offence not to do so.
But a ‘patchwork of regulation’ makes                                    •    Strict liability – fault or
                                                                              negligence is not a prerequisite
Germany a tough place for risk managers to                                    for enforcement action in some
get to grips with environmental exposures                                     industries. There is no limit on
                                                                              financial liability.
                                                                         •    Increased scope for claims

                              Germany is split into three main
                                                                              – citizens or environmental
                                                                              groups can launch their own
                                                                              claims against polluters.
01: Authorities can     •    The ‘precautionary principle’ is            •    More onerous remediation.
intervene if they            aimed at avoiding or minimising the              There are three new types:
believe there is a           possibility of pollution in the first             – primary remediation: returning
possibility of               place. Authorities can intervene and               the environment to a baseline
pollution.                   regulate facilities even if they have              condition a er pollution;
02: The polluter             not yet polluted.                                – complimentary remediation: if
must pay for all        •    The ‘polluter pays’ principle means                baseline conditions can’t be
clean-up costs.              that anyone responsible for causing                achieved then the polluter has
03: Environmental            environmental harm will be liable                  to remediate, for example by
protection is a              for the clean-up costs.                            creating a new habitat; and
subject at the          •    The ‘co-operation principle’ means               – compensatory remediation:
forefront of                 that environmental policy must be                  compensation for losses until
public opinion.              developed in close collaboration with              the primary or complimentary
04: A duty to protect        public and private organisations.                  remediation is completed.
the public means             German environmental law is mostly          •    Mandatory financial security
companies creating      governed by federal acts. Administering               – member states are developing
environmental           and enforcing the laws, however, is le to             mechanism to ensure polluters
hazards must take       its 16 states. Important federal authorities          have the capability to carry out
reasonable              include the Federal Ministry for the                  environmental remediation.
precautions to          Environment and the Federal
prevent damage.         Environment Agency.
                             “While the Federal Ministry defines        on their environmental exposures in
                        the political agenda, the Environmental        Germany. “Germany is one of the hardest
                        Agency is in charge of environmental           markets to find environmental insurance
                        research, planning and administration,”        cover because there is a patchwork of
                        Freshfields Bruckhaus Deringer partner          regulation,” Ferma’s general secretary
                        Wolf Friedrich Spieth explains.                and environment expert, Pierre Sonigo,
                             This two-tier system makes it             says. “Cover is available, but generally
                        difficult for risk managers to get a grasp     insurers are very strict with their terms.”

 4   StrategicRISK
     Added to this, and making the
climate even more onerous for business,        INSIGHT
Germany is regarded by many as an              Ferma says no to mandatory insurance
‘environmental state’, meaning that it
considers environmental protection as          ONE OF THE MAIN IMPACTS OF THE HUNGARIAN TOXIC
one of its central tasks.                      sludge disaster and the Deepwater Horizon Gulf oil spill has
     “Public opinion in Germany is             been to encourage the European Commission to reconsider its
traditionally very sensitive to                position on mandatory insurance protection for environmental
environmental issues,” Freshfields              liabilities. The Commission is currently considering a EU-wide
Bruckhaus Deringer partner Michael             compulsory scheme for all oil companies.
Ramb says. The utmost care should be                 As it stands, financial protection is compulsory in eight
applied when dealing with these issues.        European countries, but not all. Ferma, representing the interest
                                               of risk managers in Europe, is against the idea and any type of
The nitty gritty                               mandatory insurance for large risks. “We do not think there
As in most countries, the heavy                should be mandatory insurance,” says chair of Ferma’s
engineering and industrial companies           environmental liability working group, Pierre Sonigo.
(such as refineries, chemical plants and              “We feel there are sufficient solutions for the oil industry in
paper mills), which are more likely to         the commercial insurance market so there is no need to make it
harm the environment, are the subject of       mandatory. As a principle, we are against mandatory insurance,
special licensing requirements.                because we think this increases prices and removes
     If a company is directly responsible      competition.
for pollution that causes danger to public           Other options, such as self insurance, disappear for risk
health and the environment, the                managers if the government imposes mandatory insurance
authorities can take action, including         protection, says Sonigo. “The EU wants to add security by
pursuing costs for remediation measures.       creating guaranteed security schemes to pay for environmental
     Notably, Germany’s Federal Supreme        damage, because it is the government that ultimately will have
Court has eased the rules of evidence for      to pay. But this is not the way to do it.”
potential claimants and reversed the
burden of proof. The courts have also
applied the concept of a ‘duty to protect                                  In 2007, Germany adopted legislation
the public’ to environmental liability. Now,                          that implements the European
anyone creating environmental hazards                                 Environmental Liability Directive (ELD).
has a duty to take reasonable precautions                             The law closely mirrors the wording of
to prevent damage to third parties.                                   the directive, which creates several new
     According to the Federal Water Act,                              liabilities (see box, le ).
any person who introduces or discharges                                    There are two important additional
a substance into the water that changes                               provisions under the German laws. One
its physical, chemical or biological                                  is that it is the state’s discretion whether
composition is liable if damage is caused.                            to allow an operator to avoid liability
     Certain acts of environmental                                    for environmental damage by complying
degradation are also regarded as criminal                             with the conditions of a permit.
offences, including air and water pollution                                The other is that non-governmental
caused by noxious substances, waste                                   organisations are entitled to claim
disposal that endangers the environment,                              that remedial measures should be
and the unauthorised operation of                                     taken, even if they are not themselves
environmentally dangerous installations.                              affected by it. SR

                                                                                                   Strategic RISK   5

The €20m environmental
disaster that changed everything
French firms are not obligated to buy environmental insurance, but an oil spill
was a painful illustration of how as liability increases, so must financial cover

                                   by each European country add
                            complexity to the issue of environmental
                                                                            operator to decide if it’s worth buying
                                                                            insurance protection.
                                                                                Recently, France set in motion an
01: Environmental           liability and mean the risks vary across        imperative that will have major
law was already             the continent, depending on where a             implications, particularly for oil
well established in         company has facilities.                         companies transporting fuel via pipelines.
France pre-ELD.                  In addition, it is the responsibility of
02: The Bouches-            the enforcement authorities to determine        The Bouches-du-Rhône disaster
du-Rhône oil spill          how much a company will have to pay to          In August 2009, the French government
led to changes in           remediate the environmental damage              declared an environmental disaster in
the scope of the            caused by pollution. This means identical       one of Europe’s most beautiful nature
directive.                  pollution incidents could be treated very       reserves a er oil spilled from an
03: There is steady         differently, depending on the country           underground pipeline in the southern
growth in specific           and its enforcement approach.                   region of Bouches-du-Rhône. More than
insurance cover but              French environmental law was well          4,000 cubic metres of crude oil spilled
take-up remains low.        established before the Environmental            over five acres of agricultural land.
04: Firms should            Liability Directive (ELD) came along.                The pipeline, operated by the South
take advantage of           France transposed the directive in August       European Pipeline Company, reportedly
cheap cover as              2008. Unlike in other parts of Europe,          carried 23 million metric tonnes of crude
regulators ramp up          there is no legal obligation for companies      oil per year to refineries and
enforcement efforts.        to buy financial security against                petrochemical plants in France, Germany
                            environmental risks. It’s still up to the       and Switzerland. The clean-up costs were

     A question of liability: an oil spill
     in Bouches-du-Rhône covered
     over five acres of one of Europe’s
     most beautiful nature reserves

 6   StrategicRISK
around €20m, according to reports.
     In this case, the French courts ruled        INSIGHT
that the operator was not bound by strict         Insuring against the ELD
liability. As a result of the incident,
however, a change in French law means             ELD-RELATED LIABILITY IS A NEW TYPE OF LIABILITY AND IT
that heavy industrial activities will in          cannot be adequately covered by standard general third-party
future fall under a regime of strict liability.   or property insurance, Willis has warned.
That means the burden of proof falls on                A report by the broker states that some general liability
the operator to show that it is not liable        insurers have developed new wordings to extend the coverage
for the incident.                                 to include certain ELD liabilities. Brokers and insurers generally
     “The French regulator intervened             accept that the most comprehensive ELD cover is only
quickly,” says Dorothee Prunier from ACE’s        available through the specialist environmental market.
environmental practice. “But in this case              “Environmental cover is quite cheap,” chairman of Ferma’s
the loss did not enter within the ELD’s           environmental working group Pierre Sonigo says. “Getting an
strict liability regime, which means that         extension for ELD risks is generally pretty easy.”
the regulator has to prove negligence                  Environmental insurance provides cover for prevention
which makes the procedure longer.”                and remediation costs as defined under the ELD. This is not
                                                  limited to sudden or accidental and offsite clean-up only, but
Penetration remains low                           includes gradual pollution and other forms of damage to the
The incident provides insurers and risk           environment. “It is much better to have a standalone
managers with an illustration of the likely       environmental insurance policy,” Sonigo adds.
costs associated with environmental                    “Most large companies or sophisticated buyers have a
pollution. “I think most of the costs in this     standalone environmental policy. And most companies try to
case were because the pipeline was in a           get hold of a global programme.”
remote place, so it was difficult for the
operator to get access to the site to do a
clean-up,” Prunier comments.                                            pollution cases under the ELD is up and
     Large companies are beginning to                                   that clean-up costs could be 40 times
realise that the ELD has upped their                                    higher under the new directive.
environmental exposure and therefore                                         The environmental insurance market
their insurance needs, she adds. This is                                is expected to grow by 15%-25% per year,
contributing to steady growth in the                                    from a current estimated turnover of
environmental insurance market.                                         €40m. And competition is driving
     Overall, however, the take-up of                                   insurance prices down. “It is easy to find
specific environmental insurance                                         reasonable cover at a good price,”
products by France’s industrial                                         says Ferma’s environmental expert
companies remains low. Medium-sized                                     Pierre Sonigo.
businesses in particular usually refrain                                     The regulatory authorities in France,
from buying a specialist environmental                                  as in many other parts of the world, are
policy. Estimates suggest there are                                     under-resourced and therefore find it
around 10,000 policies in France. With                                  tough to enforce environmental laws
around two million industrial companies                                 everywhere and all the time. But insurers
in France, this suggests that penetration                               warn that the French authorities are
remains low.                                                            looking to beef up their enforcement
     In response to this, insurers point to                             efforts. Now is the time for companies to
evidence that suggests the frequency of                                 make sure they’re fully covered. SR

                                                                                                   Strategic RISK   7

EU directive leaves you to count the
cost of pollution on your property
But many UK businesses are underprepared and underinsured for the extra
liabilities they face a er introduction of new environmental legislation

                             Directive (ELD) has added a
                       substantial layer of liability in the UK,
                                                                    and many are simply waiting for
                                                                    something to happen.” He says this is a
                                                                    dangerous attitude that leaves businesses
01: The ELD means      says Stephen Shergold, an environmental      exposed to substantial uninsured costs
businesses can now     lawyer with SNR Denton. Before the ELD,      and reputational damage.
be held responsible    people were only concerned with                    “We are still fighting to find an
for complementary      traditional remediation costs, such as       adequate frequency of losses to be
and compensatory       removal of the pollution. Now                able to build up a good database and
remediation            complementary and compensatory               understand the exposure,” Sonigo says.
costs arising from     remediation costs can be levied as well.     “It’s always difficult to understand if the
pollution.                  Those costs will depend on how          damage would be under the ELD or
02: Little is known    the regulator chooses to enforce             existing environmental regulations.
about how the ELD      compensatory and complementary               Many regulators are sticking to existing
will work, so the      measures, says Shergold.                     environmental regulations, rather than
risks are being             There are examples of regulatory        enforcing the ELD, because that’s what
ignored by many.       authorities using the ELD to prosecute       they know.”
03: Businesses are     companies rather than using traditional
being urged to         forms of environmental regulations,          Financial fears
make sure their        because they consider it a simpler method.   Polestar Company group risk manager
insurance covers the        The Environment Agency, the UK’s        Gary Marshall says that in constrained
new liabilities.       environmental enforcer, is currently         times some companies may not buy
                       pursuing United Utilities for                environmental insurance to cover the
                       compensatory remediation a er serious        new liabilities. “There is a very developed
                       water pollution in July 2009, which          sophisticated market for environmental
                       caused the death of 6,000 fish at Three       insurance but it is an extra cost that
                       Pools Waterway in Southport. This is in      people may not be prepared to bear at the
                       addition to the €26,000 fine it also          moment, even though the legislation has
                       imposed on United and is intended to         extended the scope of our liability,” he says.
                       return the habitat to “the same level of         UK businesses are “dangerously
                       natural resource or service as would have    exposed” to the possibility of heavy fines
                       existed if the damage had not occurred”.     under the ELD, according to Aon. UK
                            But this is one of the few test cases   businesses are typically unaware of the
                       working its way through the courts.          consequences of the ELD, which holds
                       Ferma general secretary Pierre Sonigo        them financially liable for damage to the
                       says: “Companies and their risk managers     environment caused by activities on their
                       remain unsure of how the ELD will work       property, even if the damage occurred

 8   StrategicRISK
because of the activities of former owners.
This means that nearly every property          FOCUS ON
owner in Britain needs to be aware of          Where is financial protection mandatory?
the environmental history of their
property as well as the consequences
                                               BELGIUM           GERMANY           CZECH              SLOVAKIA
of current operations.
                                               Not               Not               REPUBLIC           Due to be
     “UK businesses are potentially            mandatory,        mandatory.        Due to             introduced
sleepwalking into a real crisis if             but financial      Operators of      commence           in 2012
they continue to ignore the very real          securities may    certain           in 2013 for
threat that environmental risks pose           be required       hazardous         listed
                                               once              activities        permitted
to their balance sheets,” says Aon Risk
                                               environmental     are required      activities
Solutions’ environmental director for the      damage has        to hold
UK, Europe, Middle East and Africa,            occurred          environmental
Simon Johnson.                                                   insurance
     “EU and UK regulation is increasingly
placing the blame for damage to the
environment at the feet of land owners,
so it is vital they are aware of the history
and issues involving their property.”

Priority change                                                                    HUNGARY            BULGARIA
Currently, environmental liability is not                                          Introduced         Due to
a day-to-day concern for businesses, adds                                          1 January          commence
                                                                                   2010               in 2011
Shergold. That’s because it’s still a
challenge to get a handle on what the
consequences will be. “The extent of the
new liabilities and the circumstances          PORTUGAL          SPAIN             ROMANIA            GREECE
in which they will be applied are still        Introduced        Delayed until     Introduced         Introduced
                                               1 January         May 2011          1 January          1 May 2010.
poorly understood,” he says.
                                               2010.             because           2010. Currently    Biodiversity
     That is not to say that organisations     Proof of the      industries need   only in force      also protected
aren’t aware of the risk within their          insurance to      additional time   for shipment       by national
business. They are, for example, considering   the authorities   to complete       of waste           laws
the proximity of their operations to sites     is required       their risk
                                                                 assessments to
of special scientific interest or natural
importance, says Shergold.                                       their financial
     Beyond that, the need to ensure                             guarantee
that their insurance policies will cover                         amounts                               Source: Willis
liabilities, such as those arising from
the ELD for example, may not be so
well understood.
     “A lot of businesses have extended        CURRENTLY EIGHT MEMBER STATES IN EUROPE
their general liability policies to cover      have already introduced mandatory financial provisions for
sudden and accidental events,” Shergold        the ELD. These are: Bulgaria, Czech Republic, Greece, Hungary,
says. “But there’s no certainty over           Portugal, Romania, Slovakia and Spain. The Commission is
whether those policies will respond to the     mulling a EU-wide compulsory scheme.
new types of remediation measures.” SR

                                                                                                     Strategic RISK     9

The rules may be stringent but have
companies been too slow to react?
It may be mandatory for Spanish companies                              most stringent approach to the
                                                                       implementation of the ELD.
to cover themselves against environmental
damage, but a lack of awareness lingers                                No protection
                                                                       Despite this, a survey of over 700 Spanish
over the risks and cover available                                     companies conducted by TNS Global
                                                                       Market Research and sponsored by ACE

                             Boliden mine near Seville in April
                        1998 led to one of the most harmful
                                                                       Iberia revealed a significant lack of
                                                                       awareness of environmental legislation
                                                                       and the risks affecting businesses.
01: Spain has           environmental incidents in the history              The research, published in August
adopted the             of the country. The rupture released           2011, also found a lack of knowledge
most stringent          around five million cubic metres of toxic       about the insurance protection available
approach in Europe      slurry, containing lethal levels of lead and   to protect against these risks. The
to the ELD.             heavy metals.
02: There is still a          The accident devastated the
lack of awareness       local environment, contaminating a               FOCUS ON ASSESSING
from companies          40km stretch of two local rivers as well         EXPOSURE TO THE ELD
about the legislation   as vast swathes of the surrounding
and the protection      farmland.                                        OFFICIALLY, IT IS MANDATORY TO
available to them.            In total, almost 40 tonnes of fish          get financial security against
03: A third of study    were killed, and around 5,000 geese              environmental risks in Spain. But
respondents said        and 20,000 water birds seriously                 operators are still waiting for more
they would not          harmed. Remedial activities required             information about what exactly they
protect themselves      the excavation of 12 million tonnes              need to buy to meet the legal
against a possible      of contaminated soil and resulted in             requirements. The Spanish regulators
accident.               a total economic loss in the region              have not yet defined what companies
04: Spanish             of €400m.                                        need to buy or established any
companies’ general            The disaster was particularly              specific wordings or limits.
business policies do    damaging because the Doñana                           “Spain is working on a way to
not cover them          National Park is one of Europe’s most            assess insurance limits per location
against all             important natural sites of biodiversity,         depending on the exposure and
requirements of         thanks to its lagoons, marshland and             the sensitivity of the environment,”
environmental           scrubland. It is also an important resting       continental Europe manager of
liability.              place for migratory birds, and the               environmental risk for ACE, Dorothée
                        accident occurred in the middle of               Prunier, says.
                        nesting season.                                       Businesses with operations in
                              Perhaps because the Boliden incident       Spain, as well as other regulatory
                        still looms so large in the Spanish              bodies, eagerly await the findings.
                        collective memory, Spain has adopted the

 10   StrategicRISK
showed that over half of the businesses
did not have specific environmental            TYPES OF PROTECTION
cover. But, more alarmingly, over 30%
said they would not take any action to
protect themselves against a possible
environmental accident.
    Companies said their public liability                  What is the most popular form of
and general business insurance policies                    environmental risk protection?
provided them with sufficient
environmental risk protection. But
ACE Iberia said that these products do
not conform to the requirements of
environmental liability.                                                    43%
Best intentions
The research also revealed that levels                                          Technical
of awareness of the Environmental
                                                                                reserving   5%
Liability Directive (ELD) were low, with
65% of respondents saying they were                                                 Collateral
unaware that the Spanish government                                                     2%
could make it obligatory for them to have
a fund, collateral or insurance to cover      IN A SURVEY, SPANISH COMPANIES PLACED INSURANCE AS
their business against possible               the most likely form of environmental risk protection they
environmental damage.                         would consider (43.1%). This was far ahead of other forms
     “Spanish companies are highly            including technical reserving (4.8%) and collateral (2.4%).
dedicated to the environment and              Source: TNS study, sponsored by ACE Iberia
are conscious of their role. But there is
a major lack of awareness about
current environmental legislation,
and companies would like more                 LATEST
information,” TNS research director           New soil pollution directive
Mariola Alfonso says.
     “There are two sides to this situation   THE EUROPEAN COMMISSION IS WORKING ON A NEW
because in spite of the clear lack of         directive – the Soil Management Ordinance – to complement
awareness, there is also a positive           the ELD and to define how regulators should test the quality of
attitude towards improvement,                 soil. The objective is to introduce a more systematic method for
demonstrated by the fact that one-third       testing soil contamination.
of the companies said they would be                 “This could have a significant impact in some countries,
prepared to invest to protect the             such as Eastern Europe, because these places do not have
environment.”                                 strong regulations for soil pollution,” ACE environmental
     Respondents placed insurance as          practice’s Dorothee Prunier says. “If the directive establishes a
the most likely form of environmental         new way of testing soil contamination, then it could have a
risk protection they would consider           big effect on the local regulatory environment.”
(see chart) – significantly ahead of other           Consequently, operators may be required to clean up
forms, including technical reserving and      more frequently.
collateral. SR

                                                                                                 Strategic RISK   11

The Hungarian toxic spill has
brought the ELD into sharp focus
Risk management can not be taken lightly, and even those taking
precautions can fall foul of accidents, proving adequate insurance is vital

                                Eastern Europe is “a bit of a mess”,
                         says Ferma environmental working group
                                                                         over surrounding towns, contaminating
                                                                         rivers and killing seven people.
                                                                             A dam wall at the Ajka Timföldgyár
01: Insurers are not     chairman Pierre Sonigo. Insurers are            aluminium processing plant, owned by
touching risks in        avoiding the risks there, he says, because      MAL Hungarian Aluminium Production
Eastern Europe due       there are a host of facilities with poor        and Trade Company, was breached on
to low environmental     safety records and environmental issues.        4 October 2010, unleashing a two-metre
standards.                     European insurance association, the       wave of red sludge that affected 16 square
02: Environmental        CEA, says that environmental liability is       miles of land. Hungary’s government
liability is gaining     an emerging issue in Eastern Europe and         declared a state of emergency. Experts
prominence in light      is likely to receive renewed attention          have placed the cost of clean-up at
of the ELD.              following the recent toxic spill in             around €20m (official figures are yet to be
03: Inadequate           Hungary, which has been described as            released).
insurance can result     Europe’s worst environmental disaster.              At the time of the spill, Aon warned
in serious costs to            The accident happened in the town         that the Environmental Liability
the business at fault.   of Ajka where more than 700,000 million         Directive (ELD) would “bare its teeth”
                         cubic metres of industrial waste flooded         and that the environmental disaster in


   July 1976: Toxic chemical release in Seveso suburb          Toulouse, France, moves emphasis away from ‘risk
   of Milan, Italy.                                            management’ to ‘risk mitigation’ and paves the way
   1982: First Seveso Directive, enforcing the ‘need to        for a new dangerous chemicals regulation.
   know’ principle whereby residents should be                 January 2002: Commission tables a proposal for a
   informed of local environmental risks.                      Directive on Environmental Liability.
   April 1998: Dam containing toxic waste bursts at            April 2007: Deadline for member states to
   Aznalcoâllar in southern Spain.                             implement the Environmental Liability Directive.
   December 1999: Total Erika tanker sinks off the             October 2010: A flood of toxic red sludge is
   coast of Brittany, France, spilling 20,000 tonnes of oil.   accidentally released from an aluminum processing
   January 2000: Europe publishes working paper on             plant in Hungary. It is the largest environmental
   the Prevention and Restoration of Significant                disaster in Europe since the passing of the ELD.
   Environmental Damage.                                       October 2010: Commission advises against
   September 2001: Fertiliser plant explosion in               compulsory liability scheme.

 12   StrategicRISK
Hungary should serve as a warning                  fault if they do not have suitable
about the strength of new environmental            insurance coverage in place.”
liability laws.                                         The Hungarian government has
                                                   expressed regret over the deaths and
ELD has strong teeth                               environmental damage caused by the
The broker used the incident to                    spill, but it will be aware of the political
draw attention to new ELD liabilities              and financial consequences of any action
and the benefit of insurance. Aon Risk              it takes. MAL can expect heavy fines but it
Solutions’ environmental director for              is in the interest of the government to
the UK, Europe, Middle East and Africa,            keep the company viable. If it goes
Simon Johnson, commented: “While                   bankrupt, it is the government that
most companies are good corporate                  will be le with the very heavy costs
citizens and take risk management                  of clean-up, and it would also lead to
with regards to the environment                    considerable job losses.
extremely seriously, occasionally                       While the Hungarian government
accidents or incidents beyond anyone’s             balances the need for strong punitive
control can happen.                                action against political and cost
     “Under the ELD, which has some                considerations, MAL and similar plants,
extremely strong teeth, it is entirely             both in Hungary and central and eastern
possible that an accident such as the              Europe generally, remain a “toxic
tragedy in Hungary could ultimately lead           time bomb”, according to Hungarian
to the total collapse of the company at            Greenpeace campaigner Balázs Tömöri. SR

  EU MARKETS Environmental liability insurance

    Belgium                Hungary                    GOOD
    Bulgaria               Ireland                    France                         ADVANCED
    Cyprus                 Malta                      Italy                          Germany
    Czech Republic         Poland                     Netherlands
    Denmark                UK                         Sweden

  EU Environmental Liability Directive. Most insurers say there is good cover available for ELD risks, although insurers
  will never cover 100% of ELD-related liabilities for all activities. On the other hand, risk managers tend to show less
  interest in buying cover for ELD liabilities, and this lack of interest is increased by the slowdown in the economy.
        The chart shows how European countries assess their ELD insurance market. France, Germany, Italy and
  Spain have a long-standing culture of environmental protection laws and, thus, have a rather mature insurance
  market designed to address environmental liability claims. Countries such as the UK, however, have less of an
  environmental liability culture and therefore fewer environmental liability insurance products. As for Eastern
  European countries, many are still developing a liability culture in general, meaning that the environmental
  liability insurance market is just emerging.
  Source: European Commission study on the implementation effectiveness of the ELD, November 2009

                                                                                                       Strategic RISK   13

The company that believes
prevention is better than to insure
                        Scania is in no rush to buy specific environmental insurance
01: Scania
consciously chooses     NOT ALL COMPANIES CHOOSE TO BUY             With the environmental audit, we look at
to extend the           a dedicated environmental insurance         20 categories and compare the protection
coverage of its         policy. In Scandinavia, the insurance       measures with the Scania Group-wide
general liability       manager for truck, bus and engine           standard. If it’s good, the facility gets a
policy rather than      maker Scania decided to seek an             blue mark and if it’s bad they get a red one.
buy a specific policy.   alternative form of insurance protection.   Management can quickly see that if there’s
02: It conducts              “We don’t buy a specific                a lot of blue, then we are doing well.”
environmental           environmental insurance policy,”                 This risk scorecard approach is
audits on its           Scania corporate insurance manager          popular with many large companies with
production sites to     Martin Sijmons says. “We prefer to          sophisticated risk management procedures.
try to prevent          extend the coverage of our general               Another reason Scania doesn’t buy a
pollution issues.       liability policy to include sudden and      standalone environmental policy is
03: Insurance           accidental pollution.”                      because Sijmons believes there’s a dearth
manager Sijmons              He says the emphasis is on risk        of expertise in some parts of the market.
believes brokers lack   avoidance rather than risk transfer. “We
the expertise to        have discussed internally the benefits of
understand Scania’s     a standalone environmental insurance
exposures.              policy, but ultimately we would like to     ‘No one that I have spoken
                        prevent rather than insure. That means       to so far has been able to
                        making sure that we handle things
                        properly. We don’t use any prohibited        put a financial figure on the
                        chemicals and we make sure our people        worst-case environmental
                        are protected properly.”
                             As an engineering and                   exposure for us’
                        manufacturing company, Scania is            Martin Sijmons Scania
                        prone to a host of environmental risks,
                        such as pollution from one of its many      “I don’t think brokers are properly staffed
                        workshops or production sites. “We have     on environmental insurance issues. No one
                        three production sites in Sweden and 70     that I have spoken to has been able to put
                        garage workshops,” Sijmons says.            a financial figure on the worst-case
                             He describes the environmental         environmental exposure for us.”
                        assessment process. “We make our                 But being able to identify the
                        own audits of the production units but      worst-case environmental exposure for
                        there are a lot of workshop sites, so the   his company would help demonstrate
                        intention is to do spot checks on those.    the value of purchasing insurance

 14   StrategicRISK
protection, he adds. “If I can identify
the exposure, then I can identify the
correct level of insurance. But at the
moment that’s difficult to do with
environmental liability.”
     For the time being at least, Sijmons
doesn’t think the products exist that
can match his company’s unique
requirements. “We haven’t looked at
environmental insurance products
because, in my opinion, the insurance is
quite expensive and the breadth of
cover is quite low.
     “At the moment, the risk is on our
balance sheet and we are one or two
years away from looking for a specific
environmental insurance solution.”
     Building on the environmental work
                                                                                             Not for us: Scania has not
he has already done and as part of his
                                                                                             yet purchased specific
risk assessment, Sijmons plans to map                                                        environmental insurance
out where Scania’s Swedish facilities are                                                    for its Swedish exposures

in relation to sites of specific scientific or
natural importance. The risk is greatest
close to these sites, he says.
     But in other countries, where
the environmental risk profile differs,                  ENVIRONMENTAL INSURANCE UPTAKE
Sijmons is forced to adopt an alternative
approach. “We are looking at                            A EUROPEAN COMMISSION STUDY ON THE
environmental liability policies in some                implementation of the ELD in 2009 said that, rather than
of the other jurisdictions, like Spain,                 there being “a problem in obtaining insurance for ELD
where the risk is more onerous. We                      liabilities”, there is a general lack of operator interest in
have to abide by the law so we have                     purchasing ELD-related cover. The study said operators are
to buy environmental cover there. But                   either unaware of the ELD or do not consider that it applies to
the ELD has not had much of an impact                   them. Insurers suggest greater media coverage of significant
in Sweden.” SR                                          environmental damage may be needed to increase uptake.

                                                                                                      Strategic RISK   15

How do you start to put a
price on the environment?
The Hungarian pollution disaster highlights the problem of quantifying damage
to the environment – a er all, you can not manage what you do not measure

                              of heavy rain, the retaining wall of a
                        substantial waste sludge lagoon at an
                                                                       requirement to define, as accurately and
                                                                       comprehensively as possible, the quality
                                                                       and natural status of the ecology and
01: A baseline of       aluminium production plant in Hungary          habitats that existed around the site prior
environmental           suffered a catastrophic failure. The           to the environmental damage event.
quality should be       resultant escape of large volumes of toxic
agreed with the         and corrosive liquid waste caused death        Restoration required
regulator before a      and injury to inhabitants in the nearby        Once a baseline of environmental quality
pollution event.        towns and significant amounts of                has been established, the extent of
02: If no agreement     property damage. The sludge engulfed           remediation, restoration and
exists, the regulator   large expanses of farmland and open            compensation needed to return the
may speculate as to     ground, polluting substantial tracts of        ecosystems to their pre-damage event
the environmental       land and the local river system.               status will be defined. Where no accurate
quality.                     The ensuing contamination is              description of the baseline prior to the
03: Estimating          believed to have extended over an area of      event is available, the regulator may infer
the scale of            some 40 square km, with adverse                a scope of restoration required based on a
environmental           ecological effects on natural habitats and     speculative view of the environmental
liabilities will take   within a number of interconnecting             quality prior to the event.
the form of a           rivers, including the Danube.                       It would have been preferable,
maximum probable             Hungary’s environment minister            therefore, to establish, document and
loss estimate.          described the spill as an “ecological          agree a baseline of environmental
                        disaster” and the predicted cost of            quality with the regulator prior to any
                        clean-up is estimated to be in the region      environmental damage event occurring.
                        of €20m, with the necessary remediation        Effectively defining the baseline would
                        works to take more than a year.                have involved an economic evaluation of
                             The environmental regulator is likely     the natural environment surrounding,
                        to deploy the EU’s Environmental               and in close proximity to, the site of
                        Liability Directive (ELD) as the primary       operation and including a detailed
                        piece of legislation to ensure that            descriptive account of the ecology and
                        clean-up and restoration of the                habitats that existed naturally.
                        environment is achieved, which would                Estimating the potential scale of
                        lead to the operator being fully culpable      environmental liabilities that can be
                        under the ‘polluter pays’ principle.           associated with a pollution and
                             On the understanding that ‘you            environmental damage event of this
                        cannot manage what you do not                  nature will usually take the form of a
                        measure’, there will be an initial             maximum probable loss estimate. This

 16   StrategicRISK
will include an estimate of the extent
of ecology and habitat destruction and         TOP TIPS
the possibility of wider environmental         Quantifying the environmental risks
damage that will inform the decision-
making process in respect of issues such       •    Establish the environmental baseline for each site of
as the appropriate limit of indemnity to            operation. This should include a detailed description of the
be gained should environmental                      species, habitats and ecology that exists, and a statement
insurance be considered necessary.                  on the potential sensitivity of ecosystems to pollution and
     The maximum probable loss                      environmental damage.
estimates should be based on scientific         •    Conduct a maximum probable loss analysis for each site of
evidence concerning the species,                    operation to identify and quantify the potential for
ecosystems and habitats at risk and the             environmental liabilities associated with realistic loss
potential loss scenarios envisaged.                 scenarios that could cause environmental damage.
     The ‘value’ of the environment can be     •    Establish site-specific contingency plans and emergency
defined by quantifying the value of the              response procedures to ensure that requirements to
resource the environment provides.                  prevent significant environmental damage from occurring
Resource equivalency can be employed                are effectively managed.
that takes account of the direct value         •    Review requirements of financial security and
(wood, agriculture, food, water and so on)          environmental insurance associated with the potential to
and the indirect value (walking, leisure,           cause environmental damage at individual sites of
and public open space) of the environment           operation, based on nature and scale of activity.
as provided by the ecology and habitats.

Standardised risk assessment                 and restocking of species, communities,
The implementation of the ELD in certain     habitats and ecosystems may not be
EU countries includes a requirement for      possible on a like-for-like basis.
operators of high-risk activities to hold         Requirements for actual remediation
financial security, the quantum of which      and the technical intricacies of how this
may be predicated upon a standardised        would be done will depend largely on the
risk assessment procedure describing the     requirements for complementary and
potential liability as defined for specific    compensatory remediation and the
types of operation and scale of              primary remediation or clean-up
commercial activity.                         requirements.
     It will be important also to set             It is likely the polluter will need to be
the potential limit of indemnity on a        responsive to the demands of the
site-specific assessment of the maximum       environmental regulator in terms of the
probable loss, and not simply based upon     type and amount of remediation
a generic environmental risk table.          required. A company is unlikely to be in
     Defining the requirements for            control of the loss at this stage as the
remediation should also take into account    scope of remediation needs to be agreed
the demands for complementary and            with the regulator and, as such, the cost
compensatory remediation, which              of the loss could be uncertain, unless an
research has shown could increase the        agreed baseline has been established. SR
primary remediation estimate by up to
40 times. Consideration should also be       Cliff Warman is Marsh’s Environmental
given to the fact that precise replacement   Practice leader for the EMEA region

                                                                                               Strategic RISK   17

EU’s environmental regime should
get companies running for cover
Now that the Environmental Liability Directive is in full force, many
firms could find their current insurance cover seriously wanting

                              at the EU Environmental Liability
                        Directive (2004/53/EC) (ELD) and the
                                                                      environmental damage is significant,
                                                                      ranging from the tragic release in
                                                                      western Hungary of red sludge waste
01: The EU              implications it would have on the risks       from an aluminium works and the oil
Environmental           that companies faced, their exposure to       pipeline failure in Bouches-du-Rhône in
Liability Directive     liability and what questions they needed      southern France, to more modest yet
is now in force         to ask in respect of their insurance and      locally significant releases into rivers,
across Europe.          any environmental cover.                      such as the Three Pools Waterway
02: Some countries           A year on, it is time to assess the      incident in Southport in the UK.
have bolted on          impact of the directive and to ask: what           The EU, in its update report on the
additional financial     should companies be doing to manage,          ELD, estimates that around 50 cases to
requirements.           control and transfer this risk.               date have been, or are being, dealt with
03: Research                 The ELD was implemented on 30            under the Directive. This will continue to
suggests that           April 2007, at which time all countries       rise as the regulations begin to take effect.
traditional insurance   were supposed to have transposed it into           The broad yet non-homogeneous
programmes fall         national law. In reality, this position was   transposition across the EU into national
short of providing      not fully achieved until 2010. To that        law means that multinational companies
adequate cover          extent our experience is still developing.    have to be aware and keep abreast of
for environmental            It is worth reiterating some key         these local differences. Many countries
damage.                 points about the ELD:                         have gone beyond the statutory
                        •    It covers damage to the environment,     minimum transposition, for example by
                             habitats and biodiversity, however       extending the definition of protected
                             that occurs, including pollution, but    species, or the type of operations that
                             not exclusively from pollution           have strict liability and allowable
                             incidents.                               defences – permit defence, state-of-the-
                        •    Incidents that cause damage can be       art defence, both or none.
                             sudden and accidental, gradual or
                             even a combination of the two, there     Financial security
                             is no distinction made.                  A number of countries have also put in
                        •    The operator is the principal liable     place legal requirements for operations
                             person and that person can have          that fall within the strict liability regime
                             strict liability where the operations    to demonstrate financial security
                             fall within those described in Annex     that would be able to recompense for
                             III of the ELD.                          damage under the ELD if the operator
                             Over the past 12 to 18 months, there     could not pay. To date, Portugal and
                        have been a number of incidents where         recently Bulgaria have enforced such

 18   StrategicRISK
schemes, and others, including Spain,
Greece, Hungary, the Czech Republic,           SUMMARY
Romania and Slovenia, are yet to enforce       Key considerations in buying environmental
their respective commitments. Where law        insurance for multinational programmes
and environmental insurance is available,
it is o en the preferred option.               •    Clear objectives – demonstrate financial security,
      The International Underwriting                cover uninsured exposures.
Association of London in its report            •    Programme structure and design – master, freedom of
Environmental Risks: Insured or not?                services, local and so on.
concluded that when it comes to                •    Insurer should have experience in European and
environmental liability risks, standard or          international programmes and the ability to create and
traditional programmes fall short of                support the right structure.
providing comprehensive cover. Indeed,         •    Commitment of the insurer to environmental business
the gap is widening with regulations such           as environmental damage and therefore claims may take
as the ELD extending further                        several years to resolve.
environmental liabilities and risks.           •    Coverage should include non-pollution environmental
                                                    damage, imminent threat, business activities on third-party
Costs under ELD                                     properties, and transport.
This is demonstrated in a study by             •    Access to and scope of the insurers’ expert loss control and
the French Ministère de l’Écologie, de              claims mitigation services.
l’Énergie, du Développement Durable et
de la Mer published in April 2010, which
took specific events in the past              damage, gradual pollution, own site
and assessed the costs under the new         clean-up costs and regulatory actions.
ELD regime.                                       The ELD presents a liability and
     The report concluded that costs were    exposure to new types of damage across
estimated to be around 40 times the          the EU. Costs are likely to be higher and
regulatory costs originally incurred by      potentially significant. Claims on
the companies in the late 1990s. This        environmental insurance policies covering
trend, in very broad terms, is supported     these risks are already beginning to
by North American experience with            come through, so the risk is real.
natural resource damage.                          Unless a specific environmental
     The factors above have all combined     insurance policy with coverage for these
to provide added impetus for companies       damages is part of the insurance
with multinational exposures across          programme then full coverage is highly
Europe and wider to consider not only        unlikely and companies risk a significant
if they are compliant with any local         uninsured loss.
requirement to demonstrate financial               Finally, although the ELD is European
security, but more importantly, if they      regulation, the pressures for regulations
have any potentially uninsured               that protect the environment are global
exposures.                                   and many countries have, or are in the
     Most environmental insurers now         process of, developing some form of
provide broad cover that includes the        liability for environmental damage. SR
key elements that may not be covered or
fully insured under traditional              Simon Johnson is director of Aon’s
programmes, including environmental          Environmental Services Group

                                                                                              Strategic RISK   19

Will it take many more environmental
disasters before opinions change?
A lack of data is blamed for the low take-up of ELD insurance, but unless
demand increases and brings in more statistics, the issue will only continue

                      I    N RESPONSE TO A EUROPEAN
                           Commission paper on the
                      implementation of the Environmental
                                                                      environmental damage is what’s needed
                                                                      to increase uptake. But the truth is that
                                                                      media coverage of a single loss event
                      Liability Directive (ELD), the CEA, Europe’s    won’t make any difference to the
                      insurance association, had the following        difficulties insurers have in developing
                      to say: “The insurance industry will            ELD insurance. Several losses would be
                      continue to deliver creative and                necessary for insurers to gain the
                      innovative products for ELD liabilities,        relevant data in order to build adequate
                      but considering the newness and                 capacity and price products appropriately.
                      complexity of the ELD, in conjunction
                      with the current lack of operator demand,
                      its ability to do so is best ensured within     The truth is that media
                      the context of a voluntary market.”
                            It shows that the insurance industry      coverage of a single loss
                      is against any mandatory rules dictating        event won’t make any
                      that companies purchase financial
                      provisions to pay for environmental             difference to the difficulties
                      damage. This is a view shared by Ferma,         that insurers already have in
                      which informs StrategicRISK that it
                      opposes any mandatory insurance rules.          developing ELD insurance
                            Even with some European markets
                      imposing compulsory schemes, the                      Meanwhile, a lack of strong demand
                      uptake of ELD-specific insurance across          for ELD insurance prolongs the problem,
                      the continent remains low. This guide has       as it results in a lack of statistical data,
                      explored the reasons for the slow growth        which means insurers have trouble
                      in the environmental insurance market,          assessing the risks properly.
                      which includes a lack of relevant data to             The Commission says some insurers
                      predict future claims and reluctance by         that have developed ELD policies may
                      some regulatory authorities to bring            decide that it’s no longer commercially
                      claims under the new regime.                    viable to continue to do so, as there’s so
                            Some buyers remain convinced that         little demand for them. The insurance
                      extending their general or public liability     industry, however, considers this a
                      policies is the appropriate response. It will   pessimistic view. Insurers will continue to
                      take time to convince them otherwise.           provide ELD-related products as long as
                            Insurers suggest that extensive           they have sufficient experience and
                      media coverage of a case of significant          expertise to do so at a sustainable level. SR

 20   StrategicRISK
This special report has been   Wayne Harrington, UK and Ireland manager of environmental risk, ACE
produced with input from:      wayne.harrington@acegroup.com

                               Dorothée Prunier, continental Europe manager of environmental risk, ACE

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