APP (Asia Pulp and Paper) Group

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

The company has a sustainable forestry policy that applies to all its operations.

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

The company has a responsible sourcing policy which applies to its entire supply chain.

3. High-level position of responsibility for sustainability?

The company has a Chief Sustainability Officer - Elim Sritaba.

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

0 - The License Committee who handles sustainability-related matters is headed by the company's CEO and includes its Deputy Chairman and Managing Director.

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

In 2020, 25% of senior management was female.

6. Percentage or number of women board members?

0 - Gender balance is not directly reported by the company but identified from the profiles of the Board of Commissioners and Directors. No female members were found. However, the data is between two and five years old.

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] PEFC, HCV, HCS, NYDF, TFA and Natural Capital Coalition.

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

The company supports a local ‘Green Village' programme that helped with the establishment and management of a waste bank, as well as other local eco projects, several farmer empowerment programmes and other projects.

9. Sustainability report published within last two years?

The company published its latest Sustainability Report in 2020.

10. Reports through standardised reporting systems?

The company prepared its 2020 Sustainability report in accordance with GRI standards.

11. Climate risks assessment available?

12. Natural capital assessment available?

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 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.

16. Total area of forest plantation (ha)?

1,066,840 - Total planted areas are considered from owned FMPs and the outgrower scheme area is not included. Company owned 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, having a total area of 1,066,842 ha.

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

The company provides a list of Long-term Pulpwood Suppliers. However, it does not include all suppliers under outgrower schemes (area of community forest suppliers is not reported).

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

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

600,000 - The company reports 600,000 ha as a protected forest within concessions.

20. 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.

21. Number of Forest Management Units (FMUs)?

9 - The company has shared ownership in nine of its 39 pulpwood supplier concessions.

22. Maps of forest management units (FMUs)?

The company provides names and geo-referenced maps of all the FMUs.

23. Forest management plans available for all FMUs?

Forest management plans are available for all the FMUs of the company.

24. Monitoring of forest management plan implementation available?

[Externally verified] The company makes this commitment through the PEFC International Standard (PEFC ST 1003:2018). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's PEFC certified landbank (either 100% or ≥75% and a further commitment to be 100% certified within 5 years.). The company has reported area certified under the PEFC Sustainable Forest Management scheme was increased to 95%. Monitoring plans are available in FMPS of all FMUs, however, all Public summaries are self-reported.

25. 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.

26. 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.

27. 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.

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

The company provides names and geo-referenced maps of all third-party supplying FMUs.

29. Number of company owned sawmills?

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

30. Names and locations of company owned sawmills?

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

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

10 - The company reports 10 mills.

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

The company has disclosed the name and locations of its all mills, all the mills are located in different locations in Indonesia.

33. 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.

34. 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 its sources 53% of virgin fibre from plantation forests in Indonesia, 7% imported fibre, and the remaining 40% is recycled fibre.

35. Number of third party supplying mills?

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

36. 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.

37. 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.

38. 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.

39. 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.

40. Procedures to trace raw materials to FMU level?

The company does not state and detail a process to trace raw materials to FMU level. Hence, partial point have been awarded on the basis of the SVLK and PEFC certification of the company's supply.

41. Percentage of supply traceable to FMU level?

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

The company's forest concessions are 100% PHPL-VLK (SVLK, Timber Legality Assurance System) certified.

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

100% - The company is 100% SVLK certified.

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

The company is already 100% third party certified.

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

100% - The company states that 100% of its suppliers and operations are fully SVLK certified.

46. Percentage area (ha) FSC FM certified?

47. Time-bound plan for achieving 100% FSC FM certification of FMUs or achieved 100% FSC-certification of FMUs?

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

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

In 2020, 95% of suppliers' concession areas were PEFC Sustainable Forest Management certified while the remaining 5% was certified under PHPL-VLK. Wood harvested from these areas is considered compliant with the PEFC-SFM standard as PEFC Controlled Sources.

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

95% - As of 2020, area certified under the PEFC Sustainable Forest Management scheme was increased to 95% of the total company's pulpwood suppliers' concession areas in Indonesia.

51. Commitment to zero conversion of natural ecosystems?

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

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

53. Commitment to zero deforestation?

The company provides an explicit commitment to no deforestation in its Forest Conservation Policy.

54. Commitment to zero deforestation applies to all suppliers?

The company's Forest Conservation Policy applies to all suppliers.

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

The company states "From 1st February 2013 all natural forest clearance has been suspended whilst HCV and HCS assessments are completed. No further clearance of areas identified as forest will take place".

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

[Externally verified] The company implements a Precision Forestry concept where it acquires monitoring images captured using Unmanned Aerial Vehicles (UAVs) and security patrols The information is externally verified by Bureau Veritas.

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

[Externally verified] The company has created a Forest Monitoring Dashboard for the protected conservation areas within its supply chain and a Forest Alert System to monitor the forest cover change in the protected areas in its suppliers' concession areas, based on satellite data. The information is externally verified by Bureau Veritas.

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

0.28% - The company reports that in 2020, 0.28% of its concession area (both own and suppliers') experienced forest cover change.

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

0.28% - The company reports that in 2020, 0.28% of its concession area (both own and suppliers') experienced forest cover change.

60. Commitment to restoration of deforestation/conversion?

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

61. Commitment to restoration of deforestation/conversion applies to all suppliers?

The company reports it has a restoration strategy but this could not be found. It reported on the strategy's progress, however a clear commitment with a cut-off date could not be found.

62. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company is supporting the government in the Muara Angke nature reserve on the northern coast of Jakarta for restoration of the mangrove ecosystem and also working towards the Government of Indonesia's efforts to reduce greenhouse gas emissions reduction. The information is externally verified by Bureau Veritas.

63. Biodiversity policy?

One of the company's sustainability strategy pillars is biodiversity. However, no biodiversity policy was found.

64. Biodiversity policy applies to all suppliers?

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

[Externally verified] The company has identified species of conservation concern including Shorea balangeran listed as critically endangered in IUCN Red Data List and Ramin listed in the CITES appendix II (endangered species) since 2005. The information is externally verified by Bureau Veritas.

66. 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. The company has also provided examples of forest and habitat conservation in its own reporting.

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

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

The company commits to the prohibition of hunting in its supplier's concessions only. PT. Bina Daya Bentala does not have such a commitment.

69. Commitment to protect forest areas from illegal activities?

The company has a commitment to prevent illegal logging, encroachment, and forest fires, but this does not cover all illegal activities.

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

71. 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 has also reported a 68% reduction in illegal poaching tools compared to a 2019 baseline.

72. Commitment to no use of genetically modified organisms?

The company states that it will only accept wood from forest management units free from genetically modified trees.

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

The company states that it will only accept wood from forest management units free from genetically modified trees and expects that wood suppliers comply with this commitment.

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

The company has a commitment to conduct High Conservation Value (HCV) assessments.

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

The company has a commitment to conduct High Conservation Value (HCV) assessments which applies to all suppliers.

76. High Conservation Value (HCV) assessments available?

[Externally verified] The company publishes HCV assessments for its FMUs. Assessments were conducted by Asia Pacific Consulting Solutions.

77. 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. Assessments were conducted by Asia Pacific Consulting Solutions.

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

The company commits to conduct HCS assessments, and mentions the HCS Approach.

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

The company has commitment to the High Carbon Stock (HCS) Approach which applies to all suppliers.

80. High Carbon Stock (HCS) assessments available?

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

81. 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.

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

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.

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

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

85. 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.

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

The company commits to protecting forested peatland using HCV and HCS methodologies, but does not commit to no planting on non-forested peatland.

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

The company's commitment to protecting forested peatland using HCV and HCS methodologies applies to suppliers operations, but there is no commitment to no planting on non-forested peatland.

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

50% - The company provides an approximate figure (50%) of landbank on peat in supplier concessions in its 2018 sustainability report. However, it is approximate and the figure is between two and five years old.

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

[Externally verified] The company states that it restores 10% of degraded peatland in protected areas and also sets target for the same. The information is externally verified by Bureau Veritas.

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

The company has a Peatland Management Strategy which develops and implements the peatland best management practices for peatland, however, no commitment was found for soil.

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

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

The company makes this commitment through the PEFC International Standard (PEFC ST 1003:2018). Full points have therefore been awarded on the basis of the company's PEFC certified landbank. The company only provides examples of BMP for peat in its own reporting.

93. Commitment to reduced impact logging?

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

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

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

95. Evidence of implementing reduced impact logging practices?

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

96. Commitment to zero burning?

The company imposes a strict no-burn policy.

97. Commitment to zero burning applies to all suppliers?

The company has a commitment to zero burning which applies to all suppliers.

98. 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 percentage of company landbank certified by PEFC.

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

3 - The company's Daily Fire Update reports 1: hotspots (Verified no fire), 2: hotspots (Verification in progress), 3 :hotspots (total). Total number of hotspot data is provided daily from National Institute of Aeronautics and Space of Indonesia (LAPAN) & ASEAN Specialized Meteorological Center (ASMC).

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

0.01% - The company reports the area affected by fires to be 0.01% of the total pulpwood suppliers' concessions areas in 2020.

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

The company reports carbon intensity reduction of 13% compared to 2018 baseline, against a target of 30% by 2030.

102. GHG emissions intensity?

The company reports carbon intensity figures: 0.977 tCO2e/tonne in 2020.

103. GHG emissions from land use change?

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

104. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports GHG emissions intensity figures that show a decrease since 2018: 1.152 (2018), 1.061 (2019), 0.977 (2020) tCO2e/tonne. The information is externally verified by Bureau Veritas.

105. Methodology used to calculate GHG emissions?

GHG or carbon emission assessment is based on Intergovernmental Panel on Climate Change (IPCC) and World Resources Institute (WRI)/World Business Council for Sustainable Development (WBCSD)—Greenhouse Gas (GHG) Protocol methodology.

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

The company reports a reduction in water use intensity of 8% in 2020, achieving its target of 30% reduction by 2030.

107. Water use intensity?

29 - The company reports water use intensity for the year 2020 as 29 m3 /t.

108. Progress towards commitment on water use intensity?

[Externally verified] The company reports water use intensity figures that show a decrease since 2018: 31 (2018), 31 (2019), 29 (2020) m3/t. The information is externally verified by Bureau Veritas.

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

The company has achieved a target of 10% below national and/or regional limits for COD and BOD in 2020 and sets a new target of 30% chemical oxygen demand (COD) emission lower than government regulation by 2030.

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

[Externally verified] The company reports BOD and COD figures for all its mills, but some of them show a decrease in water quality. The information is externally verified by Bureau Veritas.

111. Treatment of pulp and paper mill effluent?

[Externally verified] The company provides details on the treatment of pulp and paper mill effluent through the waste water recovery system. The information is externally verified by Bureau Veritas.

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

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

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

[Externally verified] The company reported 13% of water used in 2020 was recycled. The information is externally verified.

114. Commitment to protect natural waterways through buffer zones?

115. 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.

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

The company has a commitment for procurement of chemical substances to comply with international law and regulation, governing the use of hazardous substance.

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

The company has a commitment for procurement of chemical substances to comply with international law and regulation, governing the use of hazardous substance which applies to all suppliers.

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

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

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

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

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

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

The company does not report chemical usage for all its FMUs.

124. Implementation of commitment to reduce chemical usage?

125. Integrated Pest Management (IPM) approach?

The company reports that it has implemented the Integrated Pest Management approach in its own and suppliers' concessions in FMP (Public Summaries). Full points could not be awarded as FMPs are not externally verified.

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

[Externally verified] The company is committed to minimising waste and maximising the opportunities to reuse waste materials; the information is externally verified by Bureau Veritas.

127. Commitment to human rights?

The company is committed to human rights in the context of the United Nations frameworks.

128. Commitment to human rights applies to all suppliers?

The company's commitment to human rights applies to all suppliers.

129. Progress on human rights commitment ?

[Externally verified] The company has conducted 27,210 hours of human rights training for its employees, with the participation of over 90% of all employees, and has also focused on improving procedures, working instructions, aligning standards, and coordinating with relevant parties regarding labour compliance, and has implemented a new social and environmental internal audit in conjunction with various internal divisions. The information is externally verified by Bureau Veritas.

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

The company respects indigenous and local communities' rights, however, the commitment does not refer the UN Declaration for Indigenous Peoples or ILO Convention no. 169.

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

The company respect indigenous and local communities' rights applicable to all suppliers, however, the commitment does not refer the UN Declaration for Indigenous Peoples or ILO Convention no. 169.

132. 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.

133. 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.

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

The company has a commitment to the principle of Free, Prior and Informed Consent (FPIC) for indigenous and local communities on any proposed development or forest management activities in existing plantation areas. It also seeks to resolve conflict effectively and handle complaints responsibly.

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

The company's commitment to free, prior and informed consent (FPIC) applies to all suppliers.

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

The company has a free, prior and informed consent (FPIC) process available.

137. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] In 2020, the Regional Social Working Group in South Sumatra resolved two dispute cases that have been ongoing for fifteen years, working with EcoNusantara Lestari, to develop a practical guide that sets out a step by step process to map areas used by the community. The information is externally verified.

138. Details of process for addressing land conflicts available?

The company reports having a four-stage dispute resolution process to help monitor and report on progress.

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

[Externally verified] The company collaborates with Matha Tilaar for women empowerment in rural areas around company pulpwood suppliers and mill operations. The information is externally verified by Bureau Veritas.

140. 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.

141. 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.

142. Commitment to provide essential community services and facilities ?

The company is committed to providing essential community services and facilities.

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

The company reports multiple examples of how it provides essential community services and facilities such as water sanitation, the development of schools, and maintaining roads for the surrounding community. The information is externally verified by Bureau Veritas.

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

The company has a commitment to empowering women through business or work opportunities and has also established several farmer empowerment programmes.

145. 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.

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

The company has an Employee Welfare Policy which abides by ILO Conventions. However, it does not explicitly mention all the fundamental ILO Conventions.

147. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles 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 but the requirements do not fully meet the SPOTT indicator criteria. However, the company also has a commitment to Fundamental ILO Conventions or Free and Fair Labour Principles which applies to all suppliers.

148. Progress on commitment to respect all workers' 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 provides employees career development reviews, at least annually. Employees are free to select and join a union of their choice, and maternity and paternity leave packages are given.

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

The company states that it does not tolerate any kind of harassment or discrimination in employment practices, whether it is based on gender, ethnicity, religion, race, or disabilities.

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

The company's commitment to eliminating gender-related discrimination with regard to employment applies to all suppliers.

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

[Externally verified] The company provides a mechanism to report discrimination or any other concerns, with anonymity, and reports zero incidents of discrimination in 2020. The information is externally verified.

152. Percentage or number of temporary employees?

1,847 (5.2%) - The company reports 1,847 (5.2%) temporary employees in 2020.

153. Percentage or number of women employees?

2,461 (8.52%) - The company reports 2,461 women employees in 2020.

154. Commitment to pay a living wage?

The company commits to providing more than the minimum wage, which varies by location, irrespective of gender.

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

As per the Supplier Code of Conduct, wages and benefits paid for a standard working week must meet local and national legal standards.

156. Progress on commitment to pay a living wage?

157. Reporting of salary by gender?

The company reports salaries are 1:1 between men and women. However, the company does not report the ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation in line with GRI reporting.

158. Commitment to address occupational health and safety?

The company has a commitment to address occupational health and safety. However, the commitment does not reference the ILO Code of Practice on Safety and Health in Forestry Work, hence awarded partial points.

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

The company has a commitment to address occupational health and safety for suppliers. However, the commitment does not reference the ILO Code of Practice on Safety and Health in Forestry Work, hence awarded partial points.

160. Provision of personal protective equipment and related training?

The company reports that it provides personal protective equipment and related training in its sustainability report which has been externally verified.

161. Time lost due to work-based injuries?

2.6 - The company reports a lost day rate: Male 2.6 and Female 0.

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

10 - The company reports 10 fatalities for the year 2020.

163. Commitment to support smallholders?

The company works with rural communities to educate smallholders on the dangers of fires, and address poverty as a leading cause of fires. However, no commitment to support smallholders found.

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

[Externally verified] The company supports a local SME that turns wood container waste into furniture and handicrafts which reduced waste to landfill and improved local economic empowerment, facilitated soft loans through the Abdul Wahid cooperative managed by the CSR Team, targeting the MSME and agricultural businesses. The information is externally verified by Bureau Veritas.

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

The company support three community forests and the Integrated Forestry and Farming System, a community-forestry program has been rolled out in 386 villages, benefiting 31,418 households. Information is not externally verified.

166. 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 screen pulpwood suppliers.

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

[Externally verified] 100% - The company states that the Supplier Evaluation and Risk Assessment (SERA) tool is a mandatory process for suppliers that screens their operations. In 2020, 14 new pulpwood suppliers passed the SERA process. The information is externally verified by Bureau Veritas.

168. Suspension or exclusion criteria for suppliers?

As per the Responsible Fibre Procurement & Processing Policy, 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.

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

The company has Supplier Evaluation and Risk Assessment (SERA) tools, which acts as an initial screening to evaluate the level of risk within a new supplier's operations. Approved suppliers undergo annual SERA evaluations to ensure continued compliance company policy.

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

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

171. Commitment to ethical conduct and prohibition of corruption?

The company has a commitment to ethical conduct and prohibition of corruption.

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

The company has a commitment to both ethical conduct and prohibition of corruption (or bribery/fraud) which applies to all suppliers.

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

[Externally verified] In 2020, the company evaluated its ethics and compliance programme, and held training on the BCoC to fourteen business operations in Indonesia. The information is externally verified.

174. 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.

175. Disclosure of the company’s management approach to tax and payments to governments?

176. 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.

177. Whistleblowing procedure?

The company has a 24/7 channel for internal and external parties to ask questions and raise concerns.

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

The company has developed a grievance procedure to address any issues or concerns open to all stakeholders.

179. Details of complaints and grievances disclosed?

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