Amcor plc (安姆科（中国）投资有限公司)

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

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

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

In addition to a supplier code of conduct, the company's biodiversity and fibre sourcing policy states that it will work with suppliers to be certain they are compliant with its environment, sustainability and biodiversity and fibre sourcing policies.

3. High-level position of responsibility for sustainability?

Sustainability initiatives are centrally coordinated by the company's Vice President of Sustainability.

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

The company's Board of Directors and its committees provide input and guidance on the company's sustainability strategy as an integrated part of their oversight of the company's overall strategy and risk management.

5. Reports gender balance of senior management team?

The company reports that 18% of its top management positions are female.

6. Reports gender balance of board members?

4 - Information about the members of the company's board of directors is available on the company's website.

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 reports a list of memberships with industry schemes and external initiatives held at a global or subsidiary levels in Exhibit 7 of its 2023 Sustainability Report. Among those associated with timber and pulp production include 4evergreen, APIGRAF, Consumer Goods Forum, and European Carton Makers Association.

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

The company has collaborations with various organisations to reduce the negative environmental and social outcomes associated with timber and pulp production, however only limited details are provided.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2023.

10. Reports through standardised reporting systems?

The company has submitted multiple CDP questionnaires. It also reports that its sustainability report has been completed in line with GRI standards.

11. Climate risks assessment available?

[Externally verified] The company has submitted its CDP Climate Change questionnaire in 2023, and published its first TCFD report in 2022.

12. Natural capital assessment available?

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

13. Lists countries and operations?

The company only lists the countries in which it operates, however, it is unclear if it covers all of its forestry/paper processing business.

14. Lists countries sourcing from?

This indicator is disabled as the company reports that it does not source wood/wood fibre from third-party suppliers.

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

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

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

This indicator is disabled as the company reports that it only has plantation-based operations OR does not produce wood/wood fibre.

17. Total area of forest plantation (ha)?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

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

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

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

21. Area of Intact Forest Landscape (ha)?

This indicator is disabled as the company reports that it is not a producer with Intact Forest Landscape (IFL) within its landbank.

22. Number of Forest Management Units (FMUs)?

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

23. Maps of forest management units (FMUs)?

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

24. Forest management plans available for all FMUs?

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

25. Monitoring of forest management plan implementation available?

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

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 does not operate in a country 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 does not operate in a country 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 does not operate in a country currently covered by Open Timber Portal.

29. Maps of all third-party supplying FMUs?

This indicator is disabled as the company reports that it does not have any sawmills or pulp and paper mills OR does not source wood/wood fibre.

30. Number of company owned sawmills?

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

31. Names and locations of company owned sawmills?

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

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

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 any 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?

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

36. Number of third party supplying mills?

37. Names and locations of all third party 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?

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

42. Percentage of supply traceable to FMU level?

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

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

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

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

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

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

92% - The company reported that approximately 92% of its wood fibre-based raw materials purchased were third-party certified or equivalent.

47. Percentage area (ha) FSC FM certified?

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

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

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

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

The company reports that in FY23, approximately 92% of the wood fiber-based raw materials purchased were third-party certified or equivalent by a responsible sourcing standard, but did not specify the breakdown by standards, hence no points are awarded.

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

The company reports that in FY23, approximately 92% of the wood fiber-based raw materials purchased were third-party certified or equivalent by a responsible sourcing standard, but did not specify the breakdown by standards, hence no points are awarded.

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

This indicator is disabled as the company reports that it does not produce wood/wood fibre OR does not operate in a country with a PEFC-endorsed SFM standard.

52. Commitment to zero conversion of natural ecosystems?

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

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

The company states it continually supports and works toward a deforestation-free supply chain but the commitment is unclear.

54. Commitment to zero deforestation?

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

55. Commitment to zero deforestation applies to all suppliers?

The company states it continually supports and works toward a deforestation-free supply chain but the commitment is unclear.

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

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

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

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

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

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

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

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

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

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

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

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

64. Implementing a landscape or jurisdictional level approach?

65. Biodiversity policy?

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

66. Biodiversity policy applies to all suppliers?

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

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

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

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

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

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

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

71. Commitment to protect forest areas from illegal activities?

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

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

73. Evidence of protecting forest areas from illegal activities?

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

74. Commitment to no use of genetically modified organisms?

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

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

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

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

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

78. High Conservation Value (HCV) assessments available?

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

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

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

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

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

82. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since January 2015.

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 does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since April 2015 OR if all new planting has been undertaken since November 2017 and has been covered under combined HCV-HCS assessments.

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

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

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 does not operate in a country currently covered by Open Timber Portal.

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

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

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

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

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

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

This indicator is disabled as the company reports that it does not produce wood/wood fibre OR produces wood/wood fibre but states that it has no operations on peatland OR only has natural forest operations.

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

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

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

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

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

95. Commitment to reduced impact logging?

This indicator is disabled as the company reports that it only has plantation-based operations OR does not produce wood/wood fibre.

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

97. Evidence of implementing reduced impact logging practices?

This indicator is disabled as the company reports that it only has plantation-based operations OR does not produce wood/wood fibre.

98. Commitment to zero burning?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

99. Commitment to zero burning applies to all suppliers?

100. Evidence of fire monitoring and management?

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

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

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

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

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

The company had previously committed to achieve a 60% reduction in GHG emissions intensity by 2030, inclusive of Scopes 1, 2, and 3, compared to its 2006 baseline. However, this is a company-wide figure that is not specific to forestry operations, hence partial scoring. In June 2023, the company reported that it has submitted its proposed targets to the science-based targets initiative for approval.

104. GHG emissions intensity?

The company reports 67.0 (CO2e/ Amcor unit) GHG emission intensity. However, this is a company-wide figure that is not specific to forestry operations, hence partial scoring.

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 has natural-forest based operations OR does not produce wood/wood fibre.

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

107. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] [Externally verified] In 2023, the company reported that its emissions intensity reduced from 71.5 tCO2e/m3 to 67.0 tCO2e/m3. The data reported is independently assured. However, this is a company-wide figure that is not specific to forestry operations, hence partial scoring.

108. Methodology used to calculate GHG emissions?

Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (Revised Edition) and Corporate Value Chain (Scope 3) Accounting and Reporting Standard.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

110. Water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

111. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

114. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any sawmills OR only trades wood/wood fibre.

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

117. Commitment to protect natural waterways through buffer zones?

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

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

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

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

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

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

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

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

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

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

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?

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

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?

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

127. Implementation of commitment to minimise inorganic fertiliser usage?

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

128. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] The company has reported limited details on its waste management system related to timber and pulp operations. Reported waste data is externally verified.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

133. Commitment to respect Indigenous Peoples' and local communities' rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification.

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

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

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

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

140. Examples of local stakeholder engagement to prevent conflicts?

141. Details of process for addressing land conflicts available?

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

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

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 does not operate in a country 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 has plantation-based operations OR does not produce wood/wood fibre.

145. Commitment to provide essential community services and facilities ?

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

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

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

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

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 does not operate in a country currently covered by Open Timber Portal.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

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

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

Commitment to eliminate gender-related discrimination in employment is publicly available in the company's Code of Business Conduct and Ethics.

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

The company commits to eliminating gender-related discrimination in employment and this applies to all suppliers.

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

The company reported the number of investigations on its grievance register related to discrimination as well as establishing complaint reporting and resultion procedures for its employees.

155. Percentage or number of temporary employees?

3100 - The company reports that it hires 3,100 contractors in its FY2021 Sustainability Report. Data between two and five years old; partial points awarded.

156. Reports gender balance of employees?

22% - The company reports 22% of its entire workforce is female.

157. Commitment to pay a living wage?

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

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

The company states that it has not completed a global analysis of the ratio of basic salary and remuneration of women to men, but does report this metric as required by law in the United Kingdom and Australia.

161. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

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

The company's supplier code of conduct requires suppliers to provide a safe and healthy work environment but does not reference ILO Code of Practice on Safety and Health in Forestry Work.

163. Provision of personal protective equipment and related training?

Limited, externally verified points have been awarded on the basis of the company's FSC Chain of Custody certification (FSC-STD-40-004 V3-1) as the requirements do not fully meet the SPOTT indicator criteria.

164. Time lost due to work-based injuries?

0.46 - Lost Time Injury Frequency Rate: 0.46 (number of lost time injury per million hours worked).

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

1 - The company reported one work-related fatality in 2023.

166. Commitment to support smallholders?

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

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

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

The company reports engaging with Ecovadis which helps the company to evaluate each supplier's performance. All the strategic and critical suppliers are required to complete an assessment through the Ecovadis platform. The company also sets standards in its Supplier Code of conduct that all the suppliers are required to comply with.

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

[Externally verified] 76% - The company reports that 76% of its strategic and critical suppliers had completed an EcoVadis assessment within the past two years.

171. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

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

173. Proportion of supply from suppliers that is verified as deforestation and/or conversion-free (DCF)?

The company reports that approximately 92% of the wood fibre-based raw material purchased was third-party certified or equivalent by a responsible sourcing standard. No segregated information on direct and indirect supply is reported. This assessment was reviewed and verified by Intertek Health Sciences Inc.

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?

The company states that bribery and corruption risks are addressed through its policies and maintaining a Whistleblower Policy and an independent, externally managed whistleblower service which allows its workers to anonymously escalate and report matters including bribery and corruption. The company additionally reports that seven investigations related to bribery and corruption, and seven related to business integrity were complete in FY2023.

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 does not operate in a country currently covered by Open Timber Portal.

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

The company has a tax risk management policy that ensures that the company is fully compliant with all relevant tax legislation. This also includes information on who has tax responsibilities within the company.

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 does not operate in a country currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company reports that a confidential Whistleblower Service operated by an independent third-party service provider is established for employees to help them report anonymously and stay protected.

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

182. Details of complaints and grievances disclosed?

The company only discloses a summary of number and types of grievances.