APP (Asia Pulp and Paper) Group

1. Sustainable forestry policy or commitment for all its operations?

The company has published a sustainable forestry policy which covers all operations.

2. Sustainable forestry policy or commitment applies to all suppliers?

The company has a fibre Procurement and Processing Policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has reported that Elim Sritaba is the Chief Sustainability Officer.

4. One or more members within the board of the company have responsibility for sustainability?

The company reports that it has a License Committee which is responsible for sustainability-related matters, headed by the company's CEO, Deputy Chairman and Managing Director.

5. Percentage or number of women in senior management team?

The company reports that its senior management is 24.5% female.

6. Percentage or number of women board members?

1 - The company reports one female board member.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with timber and pulp production?

[Externally verified] The company is a member of PEFC, HCV, HCS, NYDF and TFA.

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with timber and pulp production?

The company states multiple collaboration programs such as supporting Micro, Small, and Medium Enterprises (MSMEs) in the mill and forestry, providing access to clean water and sanitation in Karawang, providing pumps for irrigation to 120 farmers in Bogem Pinggir village, disseminating scholarships in collaboration with ITSB (Institute of Technology Science Bandung) for the Pulp & Paper Program.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2021.

10. Reports through standardised reporting systems?

The company's sustainability report 2021 has been prepared in accordance with GRI standards (Core) option.

11. Climate risks assessment available?

The company has published its CDP climate questionnaire 2022, which includes a summary of climate related risks identified by the company, the process used to evaluate risks and those responsible for evaluating risks.

12. Natural capital assessment available?

The company reports that it has conducted a scoping assessment as part of plans to conduct a natural capital assessment.

13. Lists countries and operations?

Indonesia (pulp and paper mills, pulpwood suppliers and forest plantation).

14. Lists countries sourcing from?

This indicator is disabled as the company reports that it does not trade wood/wood fibre.

15. Total land area managed/controlled for forestry (ha)?

1063420 - The company reports its total concession area as 1,063,421 ha.

16. Total area of natural forest designated for wood/wood fibre production (ha)?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

17. Total area of forest plantation (ha)?

1066840 - The company reports forest area of its each FMUs. PT. Arara Abadi 296,373 ha, PT. Satria Perkasa Agung 77,702 ha, PT. Satria Perkasa Agung Serapung 11,927 ha, PT. Riau Abadi Lestari 15,226 ha, PT. Satria Perkasa Agung Sinar Merawang 10,070 ha, PT. Wirarakarya Sakti 290,378 ha, PT. Finnantara Intiga 299,700 ha, PT. Sumalindo Hutani Jaya I 10,976 ha and PT. Sumalindo Hutani Jaya II 54,490 ha. In the total area of forest plantation, outgrower scheme areas are not included.

18. Area of plantation/natural forest within outgrower schemes (ha)?

11423 - The company reports 11,423 ha of community forests, however it is not clear if this covers all outgrower/contract farming schemes.

19. Unplanted (areas designated for future development as plantation forest) (ha)?

0

20. Conservation set-aside area, including HCV area (ha)?

600000 - The company states that it has a protected area of 600,000 ha within the concession.

21. Area of Intact Forest Landscape (ha)?

This indicator is disabled as the company has reported or informed ZSL that it doesn't have any intact forest landscapes within its landbank.

22. Number of Forest Management Units (FMUs)?

9 - The company reports that it has 9 FMUs.

23. Maps of forest management units (FMUs)?

The company has reported names and georeferenced maps of all the FMUs on its website.

24. Forest management plans available for all FMUs?

The company has forest management plans available for all 9 FMUs.

25. Monitoring of forest management plan implementation available?

The company has published a public summary of all its FMUs which includes monitoring and management plans. However, all public summaries are self-reported.

26. Company has provided valid legal documents to Open Timber Portal on use right (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

27. Company has provided valid legal documents to Open Timber Portal on forest management (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

28. Company has provided valid legal documents to Open Timber Portal on timber harvesting (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

29. Names and locations of all third-party supplying FMUs?

The company has reported the names and georeferenced maps of all third-party supplying FMUs on its webpage.

30. Number of company owned sawmills?

This indicator is disabled as the company reports that it does not own sawmills.

31. Names and locations of company owned sawmills?

This indicator is disabled as the company reports that it does not own sawmills.

32. Number of company-owned pulp and paper mills?

10 - The company has 10 pulp and paper mills.

33. Names and locations of company-owned pulp and paper mills?

The company has reported the names and locations of all its mills, all are located at different locations in Indonesia.

34. Reports total volumes (or percentages) sourced by company-owned sawmills that come from company's own operations and third-parties?

This indicator is disabled as the company reports that it does not own sawmills.

35. Reports total volumes (or percentages) sourced by company-owned pulp and paper mills that come from company's own operations and third-parties?

The company states that its sources 51% from plantation fibre, 5% from imported fibre, and 44% from recycled fibre.

36. Number of third party supplying mills?

This indicator is disabled as the company reports that it does not source from supplying mills.

37. Names and locations of all third party supplying mills?

This indicator is disabled as the company reports that it does not source from supplying mills.

38. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and third parties?

This indicator is disabled as the company reports that it does not source from supplying mills.

39. Procedures to trace raw materials to country of harvest?

The company makes this commitment through SVLK certification requirements. Full points have been awarded for this indicator on the basis that 100% of the company's wood/wood fibre supply is SVLK certified.

40. Percentage of supply traceable to country of harvest?

100 - The company makes this commitment through SVLK certification requirements. Full points have been awarded for this indicator on the basis that 100% of the company's wood/wood fibre supply is SVLK certified.

41. Procedures to trace raw materials to FMU level?

Partial points have been awarded on the basis of the company's SVLK and PEFC certification.

42. Percentage of supply traceable to FMU level?

43. Time-bound plan for achieving 100% third-party legality verification of FMUs or achieved?

The company is 100% legality verified by PHPL-VLK (SVLK, Timber Legality Assurance System).

44. Percentage area (ha) verified as being in legal compliance by a third party?

[Externally verified] 100% - The company states that it is 100% SVLK certified.

45. Time-bound plan to source only wood/wood fibre that is in legal compliance verified by a third party?

The company reports that it is already 100% SVLK certified.

46. Percentage of all wood/wood fibre supply traded/processed verified as being in legal compliance by a third party?

100% - The company's suppliers and operations are 100% SVLK certified.

47. Percentage area (ha) FSC FM certified?

48. Time-bound plan for achieving 100% FSC FM certification of FMUs within 10 years?

The company is working toward re-association with FSC following the introduction of the FSC remedy framework.

49. Percentage of wood/wood fibre supply (tonnes) from all suppliers that comes from FSC FM certified areas?

50. Commitment to source only wood/wood fibre that meets FSC Controlled Wood and/or PEFC Controlled Sources requirements?

The company has reported that 93% of suppliers' concession areas were PEFC Sustainable Forest Management certified while the remaining 7% were certified under PHPL-VLK. Wood harvested from these areas is considered compliant with the PEFC Controlled Sources.

51. Percentage area (ha) PEFC certified (excluding FSC certified area)?

93% - The area certified under PEFC Sustainable Forest Management scheme was 93% of APP's total pulpwood suppliers' concession areas.

52. Commitment to zero conversion of natural ecosystems?

53. Commitment to zero conversion of natural ecosystems applies to all suppliers?

The company commits to zero natural forest conversion by its pulpwood suppliers since 2013. However, the commitment does not include all natural ecosystems.

54. Commitment to zero deforestation?

The company commits to zero deforestation.

55. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

56. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company defines deforestation as removal of HCV and HCS areas and specifies any deforestation past 1 February 2013 will not be accepted.

57. Criteria and cut-off date for defining deforestation in supplier operations?

The company defines deforestation as removal of HCV and HCS areas and specifies any deforestation past 1 February 2013 will not be accepted.

58. Evidence of monitoring deforestation and/or ecosystem conversion?

[Externally verified] The company states that it has a precision forestry concept where it acquires monitoring images captured using Unmanned Aerial Vehicles (UAVs). The information has been externally verified by SGS. However, the extent of the area being monitored, and timeframe, are unclear.

59. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

[Externally verified] The company states that since 2017, it uses RADARSAT-2 satellite technology to establish a Forest Alert System to monitor forest cover change across its suppliers' concession areas. The information has been externally verified by SGS.

60. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

0.25% - The company reports that it kept forest cover loss rate at 0.25 percent in 2021. However, it does not cover all the company's operational area.

61. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

0.25% - The company reports 0.25% of forest cover change in the protected areas across its suppliers' concession. However, no annual figure has been reported.

62. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

The company reports its progress on the strategy and target of forest restoration. However, a clear commitment with a cut-off date could not be found.

63. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

The company commits to the protection and restoration of the natural forest across its supplier's concession areas. However, a clear commitment with a cut-off date could not be found.

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company supports the Indonesian government on climate targets to achieve FOLU Net Sink by 2030. It also supports the government in the Muara Angke nature reserve on the northern coast of Jakarta for the restoration of the mangrove ecosystem. The information has been externally verified by SGS.

65. Biodiversity policy?

The company states only a general commitment to biodiversity protection with no detail given on scope and target.

66. Biodiversity policy applies to all suppliers?

67. Identified species of conservation concern, referencing international or national system of species classification?

[Externally verified] The company has identified protected species based on CITES, IUCN and government regulations such as Sumateran Tiger, Sumateran Elephant, Jelutung and Meranti. The information has been externally verified by SGS.

68. Examples of species and/or habitat conservation management?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria.

69. Commitment to no hunting or only sustainable hunting of species?

70. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

71. Commitment to protect forest areas from illegal activities?

The company commits to prevent illegal logging, encroachment, and forest fires. However, this does not cover all illegal activities.

72. Commitment to protect forest areas from illegal activities applies to all suppliers?

73. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. The company also states that it has Collaborative Conservation Management program aimed to tackle illegal logging in company's landscape.

74. Commitment to no use of genetically modified organisms?

The company reports it only accepts wood free from genetically modified trees from its forest management units.

75. Commitment to no use of genetically modified organisms applies to all suppliers?

The company commits all suppliers to not use genetically modified organisms or transgenic species.

76. Commitment to conduct High Conservation Value (HCV) assessments?

The company commits to conduct HCV assessments.

77. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

The company commits all suppliers to conduct HCV assessments.

78. High Conservation Value (HCV) assessments available?

[Externally verified] The company publishes HCV assessments for all its FMUs. Asia Pacific Consulting Solutions has conducted the assessments.

79. High Conservation Value (HCV) management and monitoring plans available?

[Externally verified] The company publishes HCV assessments for its FMUs that include management and monitoring plans. Asia Pacific Consulting Solutions has conducted the assessments.

80. Commitment to the High Carbon Stock (HCS) Approach?

The company commits to apply the HCS Approach, as defined by the HCS Approach Toolkit.

81. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

The company commits all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit.

82. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

83. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

84. Commitment to conduct social and environmental impact assessments (SEIAs)?

The company commits to conduct social and environmental impact assessments.

85. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

The company commits all suppliers to conduct social and environmental impact assessments.

86. Social and environmental impact assessments (SEIAs) available, and associated management and monitoring plans?

87. Company has provided valid legal documents to Open Timber Portal on impact assessments (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

88. Commitment to no planting on peat of any depth?

The company states its commitment to protecting forest peatland using HCV and HCS methodologies. However, it does not commit to no planting on non-forested peatlands.

89. Commitment to no planting on peat of any depth applies to all suppliers?

The company states its commitment to protect forest peatland using HCV and HCS methodologies applies to supplier's operation. However, a commitment to no planting on non-forested peatland could be found.

90. Landbank or planted area on peat (ha)?

The company has reported the peat area of its two FMUs (PT. Satria Perkasa Agung, and PT. Arara Abadi) and also reported peatland that has been retired for conservation purpose. However, it does not cover the full scope of a company's operations.

91. Implementation of commitment to no planting on peat of any depth?

[Externally verified] The company states that 80% of peat dome peak areas have been restored. The information has been externally verified by SGS.

92. Commitment to best management practices for soils and peat?

The company commits to best management practices for peat only.

93. Commitment to best management practices for soils and peat applies to all suppliers?

The company commits all suppliers to best management practices for peat only.

94. Evidence of best management practices for soils and peat?

Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. The company also provides examples like the use of LiDAR (Light Detection and Ranging) technology to understand peat distribution and typology.

95. Commitment to reduced impact logging?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

96. Commitment to reduced impact logging applies to all suppliers?

This indicator is disabled as the company reports to only source from plantations.

97. Evidence of implementing reduced impact logging practices?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

98. Commitment to zero burning?

The company commits to zero burning.

99. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

100. Evidence of fire monitoring and management?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company has also published a fire management magazine which includes fire monitoring and management activities. However, it is two to five years old.

101. Details/number of hotspots/fires in company FMUs?

3 - The company's Daily Fire Update reports 3 hotspots in total.

102. Details/number of hotspots/fires in suppliers operations?

0.025% - The company managed to keep areas affected by fires at 0.025% of the total pulpwood suppliers' concessions areas in 2021.

103. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

The company commits to reduce GHG emissions intensity by 30% by 2030 from 2018 baseline. This figure also includes scope 1 and scope 2 emissions.

104. GHG emissions intensity?

The company reports carbon intensity figures as 1.01 tCO2e/tonne in 2022. This includes scope 1, 2, and 3 emissions.

105. GHG emissions from land use change in company's own operations (scope 1)?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

106. GHG emissions from land use change in supplier operations (scope 3)?

The company reports 19,079,318 tCO2e biogenic scope 3 emissions.

107. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports GHG emissions intensity figures have stayed the same between 2021 and 2022.

108. Methodology used to calculate GHG emissions?

The company uses Intergovernmental Panel on Climate Change (IPCC) and the World Resources Institute (WRI)/World Business Council for Sustainable Development (WBCSD) Greenhouse Gas (GHG) Protocol methodology to calculate GHG emissions.

109. Time-bound commitment to improve water use intensity?

The company commits to reducing water intensity by 30% by the year 2030 from a baseline of 2018.

110. Water use intensity?

29.7 - The company reports water use intensity as 29.7 m3 /t in 2021.

111. Progress towards commitment on water use intensity?

[Externally verified] The company reports a decrement in the water use intensity figures i.e. 2018: 33, 2019: 32.7, 2020: 30.3, 2021: 29.7 m3/t. The information has been externally verified by SGS.

112. Time-bound commitment to improve water quality (BOD or COD)?

The company commits to reduce COD levels by 30% by 2030.

113. Progress towards commitment on water quality (BOD or COD)?

[Externally verified] The company reports BOD and COD figures for all its mills. However, all mills are not showing improvement in water quality. The information has been externally verified by SGS.

114. Treatment of pulp and paper mill effluent?

[Externally verified] The company has reported several initiatives like the use of Bio Sludge Machine, mixing of wastewater sludge with waste bark for the treatment of pulp and paper mill effluents. The information has been externally verified by SGS.

115. Evidence of sawmill run-off containment and wastewater treatment?

This indicator is disabled as the company reports that it does not own sawmills.

116. Proportion of processing facilities with closed-loop water treatment system?

[Externally verified] The company reports that 14% of water used in 2022 was recycled. The information has been externally verified by SGS.

117. Commitment to protect natural waterways through buffer zones?

118. Implementation of commitment to protect natural waterways through buffer zones?

Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria.

119. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

The company ensures that the procurement and use of chemicals comply with national and international laws and regulations.

120. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

The company's commitment to procure and use chemicals that comply with national and international laws and regulations, applies to all suppliers.

121. Evidence of eliminating chlorine and chlorine compounds for bleaching?

122. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

123. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

124. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

125. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

126. Chemical usage per ha or list of chemicals used?

The company reports chemical usage for some FMUs only.

127. Implementation of commitment to minimise inorganic fertiliser usage?

The company states that it uses bio fertilisers in plantations. However, only limited details are available. The information has been externally verified by SGS.

128. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company also reports that it implements an integrated pest management approach through the public summary of its FMUs.

129. Waste management system in place to avoid negative impacts?

[Externally verified] The company has waste management systems like the circular bioeconomy (CBE) approach which aims to transition the company to zero-waste. The information has been externally verified by SGS.

130. Commitment to human rights?

The company commits to the UN Guiding Principles on Business and Human Rights.

131. Commitment to human rights applies to all suppliers?

The company commits to the UN Guiding Principles on Business and Human Rights and this commitment applies to all suppliers.

132. Progress on human rights commitment ?

[Externally verified] The company reports that it provides 29,807 hours of human rights training to its employees. In 2021, the company collaborated with the Gita Buana Foundation to work on its commitment to human rights and indigenous peoples. This information has been externally verified by SGS.

133. Commitment to respect indigenous and local communities' rights?

The company respects indigenous and local communities' rights. However, it does not refer to the UN Declaration or ILO Convention no. 169.

134. Commitment to indigenous and local communities' rights applies to all suppliers?

The company's commitment to respect indigenous and local communities' rights applies to all its suppliers. However, it does not refer to the UN Declaration or ILO Convention no. 169.

135. Commitment to respect legal and customary land tenure rights?

The company makes this commitment through SVLK certification requirements. Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria. The company also commits to respecting customary land tenure rights.

136. Commitment to legal and customary land rights applies to all suppliers?

The company makes this commitment through SVLK certification requirements. Partial points have been awarded for this indicator on the basis that 100% of the company's wood/wood fibre supply is SVLK certified and the requirements do not fully meet the SPOTT indicator criteria. The company's commitment to respecting customary land tenure rights also applies to its suppliers.

137. Commitment to free, prior and informed consent (FPIC)?

The company commits to Free, Prior and Informed Consent (FPIC) for indigenous and local communities. It also seeks to resolve conflict effectively and handle complaints responsibly.

138. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

The company's commitment to Free, Prior and Informed Consent (FPIC) for indigenous and local communities, applies to all suppliers.

139. Details of free, prior and informed consent (FPIC) process available?

The company reports the details of how the FPIC principle is operationalised.

140. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company states it started piloting dispute resolution using a village-level approach where it works with village authorities instead of individual claimants to resolve conflict. The company also trained its staff on how to undertake dispute mapping and develop action plans to resolve disputes. This information has been externally verified by SGS.

141. Details of process for addressing land conflicts available?

The company has four-stages in land dispute resolution process. This helps in monitoring and reporting on progress.

142. Supports the inclusion of women across forestry operations, including addressing barriers faced?

[Externally verified] The company states that it collaborates with the government to assist MSME Griya Batik Kaputren in Sengguruh Village, Malang in achieving women's economic empowerment. The company also supports 82 women's groups through its DMPA program aiming to improve livelihoods, transfer knowledge, improve collaboration, and create a virtuous circle of forest management. This is externally verified information.

143. Company has provided valid legal documents to Open Timber Portal on population rights (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

144. Commitment to enable sustainable use of non-timber forest products (NTFPs) by local communities?

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

145. Commitment to provide essential community services and facilities ?

The company commits to providing essential services and facilities to communities.

146. Progress on commitment to provide essential community services and facilities?

The company has provided several essential services like building traffic easing roads and bridges, providing irrigation pumps to farmers, development of schools and proper water sanitation. This is externally verified information.

147. Commitment to provide business/work opportunities for local communities?

The company commits to providing employment opportunities to local people.

148. Company has provided valid legal documents to Open Timber Portal on labour regulations (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

149. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company commits to all fundamental ILO conventions.

150. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

The company's commitment to all fundamental ILO conventions applies to all its suppliers.

151. Progress on commitment to respect all workers' rights?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. In addition, the company also states that it provides maternity and paternity leave benefits to employees and has given the freedom to all employees to join and form labor unions of their choice.

152. Commitment to eliminate gender related discrimination with regards to employment?

The company commits to preventing employment related discrimination based on gender.

153. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

The company's commitment to preventing employment related discrimination based on gender applies to all suppliers.

154. Progress on commitment to eliminate gender related discrimination with regards to employment?

[Externally verified] The company provides a confidential service for employees to report discrimination or any other concerns anonymously through an Integrated Call Centre (ICC). It also states that no gender discrimination cases have been reported in 2021. This information has been externally verified by SGS.

155. Percentage or number of temporary employees?

1612 (5.12%) - The company reports 1,612 temporary employees in 2021.

156. Percentage or number of women employees?

2289 (7.27%) - In 2021, 2,289 employees were women.

157. Commitment to pay a living wage?

The company commits to providing more than the minimum wage but no information on living wages could be found.

158. Commitment to pay a living wage applies to all suplliers?

The company's commitment to providing minimum wage also applies to its suppliers.

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

The ratio of salaries between men and women is 1:1. However, the ratio of the basic salary of women to men for each employee category, by significant locations of operation in line with GRI reporting has not been reported.

161. Commitment to address occupational health and safety?

The company commits to address occupational health and safety. However, the commitment does not refer to the ILO Code of Practice on safety and health in forestry work.

162. Commitment to address occupational health and safety applies to all suppliers?

The company's commitment to addressing occupational health and safety also applies to its suppliers. However, the commitment does not refer to the ILO Code of Practice on safety and health in forestry work.

163. Provision of personal protective equipment and related training?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC.

164. Time lost due to work-based injuries?

The company reports lost time injury frequency rate (LTIFR) for its mills and forestry operation.

165. Number of fatalities as a result of work-based accidents?

4 - The company reports 4 fatalities in 2021.

166. Commitment to support smallholders?

167. Programme to support outgrower scheme and/or independent smallholders?

[Externally verified] The company supports a community-based forest restoration and protection program, provides a business incubation course for 40 Micro, Small, and Medium Enterprises (MSMEs) in the mill and forestry operations, works on community empowerment as well as socialisation and education on the danger on fire. The information is externally verified by SGS.

168. Number or percentage of outgrower scheme and/or independent smallholders involved in programme?

[Externally verified] 31600 - The company reports that its DMPA program achieved 394 villages with potential beneficiaries of more than 31,600 households. This information has been externally verified by SGS.

169. Process used to prioritise, assess and/or engage suppliers on compliance with company's policy and/or legal requirements?

The company has a Suppliers Evaluation and Risk Assessment (SERA), which provides a system to prioritise, assess or engage suppliers on compliance with company's policy.

170. Number or percentage of suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

[Externally verified] The company reports that SERA is a mandatory tool for suppliers that screens their operations and in 2020, 14 new pulpwood suppliers had passed the SERA process. The information is externally verified by Bureau Veritas. However, it is between two to five years old.

171. Suspension or exclusion criteria for suppliers?

The company reports that the suppliers who breach the legal requirements and the provisions of the policy shall be immediately warned and, for repeated violations, have their contracts reviewed for termination.

172. Timebound action plans (including Key Performance Indicators) for suppliers to be in compliance with timber and pulp sourcing commitments?

The company performs an initial screening and evaluation of risk for the new suppliers' operations through its Supplier Evaluation and Risk Assessment (SERA) tools. Approved suppliers undergo annual SERA evaluations to ensure continued compliance with company's policy.

173. Proportion of direct and indirect supply that comes from FMUs which are compliant with timber and pulp sourcing policies?

[Externally verified] The company reports that all of its pulpwood suppliers comply with its Forest Conservation Policy. The information is externally verified by SGS.

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

175. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

The company commits all suppliers to ethical conduct and prohibition of corruption.

176. Progress on commitment to ethical conduct and prohibition of corruption?

[Externally verified] The company reports that it provided BCoC training to more than 29,000 employees in 2021. The company has also conducted fraud risk assessments, vendor due diligence reviews and ethics investigations. Information is externally verified by SGS.

177. Company has provided valid legal documents to Open Timber Portal on legal registration (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

178. Disclosure of the company's management approach to tax and payments to governments?

The company provides limited details about its approach to tax payments.

179. Company has provided valid legal documents to Open Timber Portal on taxes, fees and royalties (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company states that everyone can report unethical conduct securely and confidentially through its Integrated Call Center (ICC). ICC is a 24/7 Speak Up channel for the company's internal and external parties to ask questions and raise concerns which is described in detail.

181. Own grievance or complaints system open to all stakeholders?

The company has a grievance mechanism open to all stakeholders with a clear description of steps taken.

182. Details of complaints and grievances disclosed?

The company has disclosed a grievances list which includes the date, source, a summary of the complaint, status of the grievance and the date of feedback.