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 of Sustainability Officer.

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

The Sustainability Committee Board 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?

The company reports 6% female employees in the mill management, and 15% female employees in management, however no figures are reported for the senior management team.

6. Percentage or number of women board members?

0 - Gender balance not directly reported by the company but identified from the names of the Board of Commissioners and Directors. No female member found.

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, 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' program which brings together a range of stakeholders to cooperate in establishing a waste bank, community biogas project, catfish farming, and creating green spaces within the community. Also, the company collaborates with many other agriculture and forestry companies to make a positive impact on forest protection.

9. Sustainability report published within last two years?

Sustainability Report 2019.

10. Reports through standardised reporting systems?

The report has been prepared in accordance with GRI standards but no report has been published on the GRI database.

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

Indonesia (pulp and paper mills, pulpwood suppliers).

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)?

1,063,550 - Total planted areas are considered from owned FMPs and the outgrower scheme area is not included. Company owned FMUs: PT. Arara Abadi 296,262 ha; PT. Satria Perkasa Agung: 77,702 ha; PT. Satria Perkasa Agung Serapung: 11,970 ha;PT. Riau Abadi Lestari: 12,000 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. Total = 1,063,548 ha.

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

The company reports the area of its long term exclusive suppliers, but 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 the concession.

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 38 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?

FMPs are available for all FMUs.

24. Monitoring of forest management plan implementation available?

The company reports performance against management objectives in all management plans for each FMU. However, these reports are not externally verified therefore full points cannot be awarded. Points for limited external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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 doesn't own sawmills.

30. Names and locations of company owned sawmills?

This indicator is disabled as the company reports that it doesn't 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 discloses names and locations for all mills.

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

This indicator is disabled as the company reports that it doesn't own sawmills.

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

35. Number of third party supplying mills?

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't 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/or third parties?

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

The company states that is has procedures to trace raw materials to country of harvest, and also prooves this statement through SVLK certification requirements. Full points have been awarded for this indicator on the basis that 100% of the company's wood/woodfibre supply is SVLK certified.

39. Percentage of supply traceable to country of harvest?

100 - Full points have been awarded for this indicator on the basis of the company's 100% SVLK certification of wood/woodfibre supply.

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. 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 2019, 92%% of suppliers' concession areas were PEFC Sustainable Forest Management certified while the remaining 8% were PEFC Controlled Source.

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

92% - As of 2019.

51. Commitment to zero deforestation or zero conversion of natural ecosystems?

The company has a commitment to zero deforestation.

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

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

53. Criteria and cut-off date for defining deforestation?

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"".

54. Evidence of monitoring deforestation?

[Externally verified] The company discloses SMART (Spatial Monitoring and Reporting Tool) which is a digital tool for recording any findings during on the ground monitoring activities spatial based. The information is externally verified by Bureau Veritas.

55. Evidence of monitoring deforestation in supplier operations?

The company states in its sustainability report that it has extended the SMART system to the Musi Banyuasin supply area of South Sumatra and in the Riau Province. The exact extent of area being monitored and time-frame are unclear, as these are pilot projects. However, the company also reports that more than 20% of the total concession areas managed by it and its suppliers (over half a million ha) are monitored using RADARSAT-2 radar imaging, and that alerts are delivered to the company within 3 working days.

56. Amount of illegal/non-compliant deforestation recorded?

0.35% - The company reports that in 2019, 0.35% of its concession area (both own and suppliers') experienced forest cover change. However, this figure only covers protected areas.

57. Amount of illegal/non-compliant deforestation recorded in supplier operations?

0.35% - The company reports that in 2019, 0.35% of its concession area (both own and suppliers') experienced forest cover change. However, this figure only covers protected areas.

58. Commitment to restoration of non-compliant deforestation/conversion?

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 beyond which deforestation or conversion could not be found.

59. Commitment to restoration of non-compliant 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 beyond which deforestation or conversion could not be found.

60. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company worked with the Government of Indonesia to finalise the restoration plan for specific peatland areas and also work towards Indonesia's Nationally Determined Contribution (NDC) towards carbon emissions reduction. The information is externally verified by Bureau Veritas.

61. Commitment to biodiversity conservation?

62. Commitment to biodiversity conservation applies to all suppliers?

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

[Externally verified] The company reports that it identifies species protection as listed on the IUCN Red List of Critical Endangered Species and CITES. The information is externally verified by Bureau Veritas.

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

Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume.

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

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

The company has a commitment to sustainable hunting of species for some of its suppliers but companies such as PT. Bina Daya Bentala does not have such a commitment.

67. Commitment to protect forest areas from illegal activities?

The company commits to prevent illegal logging, encroachment, and forest fires, but this does not cover all illegal activites, such asunauthorised or illegal resource use or settlement.

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

69. Evidence of protecting forest areas from illegal activities?

Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume.

70. 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.

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

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

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

The company has a commitment to conduct HCV assessments.

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

The company has a commitment to conduct HCV assessments that applies to all suppliers.

74. High Conservation Value (HCV) assessments available?

The company publishes HCV assessments for its FMUs. Full points cannot be awarded as the assessments are not externally verified.

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

The company publishes HCV assessments for its FMUs that include management and monitoring plans. Full points cannot be awarded as the assessments are not externally verified.

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

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

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

The commitment to conduct assessment applies to all suppliers.

78. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company reports that it hasn't expanded its plantation area since January 2015.

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

The company only mentions social impact assessments, and mention them in relation to CSR programmes. Partial points have been awarded on the basis of the company's SVLK certification.

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

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

82. 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.

83. 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.

84. 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.

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

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

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

The company reports that 7,000 ha of pulpwood plantation have been retired from critical peatland for conservation purpose since 2013. However, it is unclear when that happens and whether the overall landbank on peat has decreased.

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

The company mentions a commitment to best management practices for peat. Details for each FMU's soil management methods can be found on each FMU's webpage, from the Suppliers webpage.

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

Details for each supplier's soil management methods can be found from the Suppliers webpage, but it is unclear whether the commitment to best management practices for peat applies to all suppliers.

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

The company provides best management practices for peat and details for each FMU's soil management methods can be found on each FMU's webpage, from the Suppliers webpage.

90. Commitment to reduced impact logging?

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

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

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

92. Evidence of implementing reduced impact logging practices?

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

93. Commitment to zero burning?

The company adheres to the No Burn Policy.

94. Commitment to zero burning applies to all suppliers?

The company imposes its No Burn Policy to all suppliers.

95. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's PEFC certification.

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

The company publishes daily fire updates that report the number of hotspots and fires per province.

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

1.69% - The company reports 1.69% of suppliers' concessions were impacted by the forest fire in 2019.

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

The company reports a 23% reduction in carbon intensity between 2012 and 2019, achieving its target of 10% reduction by 2020.

99. GHG emissions intensity?

The company reports carbon intensity figures: 1.06 tCO2e/ton in 2019.

100. GHG emissions from land use change?

This indicator is disabled as the company reports that it hasn't expanded its plantation area since January 2015.

101. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports GHG emissions intensity figures that show a decrese since 2015: 1.41 (2015), 1.35 (2016), 1.20 (2017), 1.15 (2018), 1.06 (2019) tCO2e/ton.

102. Methodology used to calculate GHG emissions?

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

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

The company reports a 31% reduction in water use intensity between 2013 and 2019, achieving its target of 10% reduction by 2020.

104. Water use intensity?

18.6 - The company reports water use intensity for the year 2019 as 18.6 m3 /t.

105. Progress towards commitment on water use intensity?

[Externally verified] The company reports water use intensity figures that show a decrease since 2017: 24 (2017), 20.5 (2018), 18.6 (2019) m3/ton. The information is externally verified by Bureau Veritas.

106. Time-bound commitment to improve water quality (BOD and COD)?

The company reported having maintained a commitment to remain have COD and BOD at 10% below national and regional limits. However, this was reported more than two years ago.

107. Progress towards commitment on water quality (BOD and 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.

108. Treatment of pulp and paper mill effluent?

[Externally verified] The company provides details on the treatment of pulp and paper mill effluent in its sustainability report. The information is externally verified by Bureau Veritas.

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

This indicator is disabled as the company reports that it doesn't own sawmills.

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

[Externally verified] 14% of water used in 2019 was recycled. Figure is assured by Bureau Veritas.

111. Commitment to protect natural waterways through buffer zones?

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

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

Some FMUs have a commitment to minimise the use of pesticides.

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

Some FMUs have a commitment to minimise the use of pesticides.

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

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

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

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

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

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

The company does not report the chemical use per ha for all FMUs.

121. Implementation of commitment to reduce chemical usage?

122. 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.

123. 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 through 3R-Reduce, Reuse and Recycle, and details how it does so in its sustainability report. The information is externally verified by Bureau Veritas.

124. Commitment to human rights?

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

125. Commitment to human rights applies to all suppliers?

The company provides a commitment to human rights that applies to all suppliers.

126. Progress on human rights commitment ?

The company expects all its employees to comply with the code of conduct (Human Rights Commitment) and provides training for the same. It also has developed Supplier Evaluation and Risk Assessment (SERA) tools to evaluate suppliers on 12 indicators one of them is 'Company's respect for traditional civil and human rights. The evidence is not externally verified therefore full points cannot be awarded.

127. 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.

128. 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 suppliers, however, the commitment does not refer the UN Declaration for Indigenous Peoples or ILO Convention no. 169.

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

The company makes this commitment through SVLK certification requirements. As SVLK requirements do not fully meet the SPOTT indicator criteria, partial points have been awarded on the basis of the company's SVLK certification.

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

The company makes this commitment through SVLK certification requirements. As SVLK requirements do not fully meet the SPOTT indicator criteria, partial points have been awarded for this indicator on the basis that 100% of the company's wood/woodfibre supply is SVLK certified.

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

The company commits to FPIC.

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

The company has a commitment FPIC that applies to all suppliers.

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

The company details its FPIC process on its website and in a 2019 progress report.

134. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company has a Regional Social Working Group, maps land disputes, and aims to establish a Social and Security Division to handle conflicts. The information is externally verified by Bureau Veritas.

135. Details of process for addressing land conflicts available?

The company has a land dispute resolution process detailed on its website.

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

[Externally verified] The company states that it "encourages alternative livelihoods that are free of deforestation risk by empowering women in rural areas around APP pulpwood suppliers and mill operations", among other initiatives targetting women empowerment. The information is externally verified by Bureau Veritas.

137. 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.

138. 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.

139. Commitment to provide essential community services and facilities ?

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

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

[Externally verified] The company reports multiple examples on how it provides essential community services and facilities. The information is externally verified by Bureau Veritas.

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

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

142. 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.

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

The company in Employee Welfare Policy abide by ILO Conventions. However, It does not explicitly mention all the fundamental ILO Conventions.

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

The company makes this commitment through SVLK certification requirements. As SVLK requirements do not fully meet the SPOTT indicator criteria, partial points have been awarded on the basis of the company's SVLK certification.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's SVLK certification. As SVLK requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

146. 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.

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

The company states "Suppliers not engage in discrimination in hiring, compensation, access to training, promotion, termination, and/or retirement based on race, color, sex, national origin, religion, age, disability, gender identity".

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

149. Percentage or number of temporary employees?

15,946 - The company reported 15,946 indirect employees in 2017, including contractors and seasonal workers, however this was reported more than 2 years ago.

150. Percentage or number of women employees?

7% - The company reports the percentage of women in the workforce in mills (7%), but it does not cover the whole scope of operations.

151. Commitment to pay at least minimum wage?

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

152. Commitment to pay at least minimum wage applies to all suppliers?

The company has a commitment to pay minimum wage which applies to all suppliers.

153. Progress on commitment to pay at least minimum wage?

[Externally verified] The company only states that each of its mills pays equal to or more than the local minimum wages.

154. Reporting of salary by gender?

155. Commitment to address occupational health and safety?

The commitment does not refer to the ILO Code of Practice on Safety and Health in Forestry Work.

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

The commitment does not refer to the ILO Code of Practice on Safety and Health in Forestry Work.

157. Provision of personal protective equipment and related training?

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

158. Time lost due to work-based injuries?

5.3 - As per the Sustainability Report- 2019 lost day rate is Male (5.2) and Female (0.1). However, it does not cover all operations (only mills).

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

11 - The company reports 11 fatalities for the year 2019 in the Sustainability Report. However, this does not cover all operations (only mills).

160. Commitment to support smallholders?

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

[Externally verified] The company mentionst the training of 40 farmers in urban farming (hydroponics) across 6 villages, support of a local SME who is responsible for utilising wood container waste for the production of furniture and handicraft, and a community engagement program that aims to create greater diversification of livelihoods. The information is externally verified by Bureau Veritas.

162. Percentage of outgrower scheme and/or independent smallholders involved in programme?

[Externally verified] The company support 3 community forests and the Integrated Forestry and Farming System, a community-forestry program has been rolled out in 324 villages, benefiting 7,783 households. However, the number of smallholder suppliers (outgrower scheme and/or independent) supported is unclear. The information is externally verified by Bureau Veritas.

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

The company has developed a Supplier Evaluation and Risk Assessment (SERA) tool to facilitate the implementation of its purchasing policy cross the fiber supply chain. Its process is described in the sustainability report.

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

[Externally verified] 100% - The company reports that 100% of its pulpwood suppliers have been assessed with its SERA tool. The information is externally verified by Bureau Veritas.

165. Suspension or exclusion criteria for suppliers?

All the suppliers are required to comply with the Responsible Fibre Procurement and Processing Policy. Also, the company has developed SERA to evaluate the suppliers. Suppliers who violate or are in non-compliance with the policy are warned immediately and are expected to take corrective measures within an agreed time or else the contract will be revoked.

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

The company conducts Supplier Evaluation and Risk Assessment (SERA) for all new suppliers before they are included, and evaluate them again annually.

167. 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 100% of its suppliers have passed the Supplier Evaluation and Risk Assessment (SERA) and are compliant with its purchasing policy. The information is externally verified by Bureau Veritas.

168. Commitment to ethical conduct and prohibition of corruption?

The company reports not condone corruption in all its forms, including extortion and bribery.

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

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

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

[Externally verified] The company's s Corporate Risk and Integrity Division (CRI) continued to focus on our four-pillar approach to oversee ethics and risk management within the business; asset protection, integrity management, fraud prevention, and business ethics. The information is externally verified by Bureau Veritas.

171. 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.

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

173. 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.

174. Whistleblowing procedure?

The company has "ECC: an official channel for reporting fraud, misuse of authority and assets, collusion, conflict of interest, and any other misconduct that might happen in the workplace", and specifies how issues raised are handled and whistleblowers protected.

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

The company has a grievance page accessible to all.

176. Details of complaints and grievances disclosed?

The company publishes a grievances list (last updated March 2020) that includes: issue raised, identity of the complainant, actions taken, status of the grievance, and date feedback was given.