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Headquartered in Singapore, APP China Group is the sister company of Asia Pulp and Paper

  • Parent company:
    Sinar Mas Group
  • Landbank (timber/pulp):
    288,208 hectares
  • Thomson Reuters ticker:
    Private company
  • Bloomberg ticker:
    Private company
  • Activities:
    Pulpwood production, pulp and paper production, trading and distribution
  • Locations:
    China (Hainan, Guangdong, Guangxi, Yunnan, Jiangxi, Henan, Liaoning, Sichuan, Hubei, Fujian, Shandong, Jiangsu, Zhejiang provinces)
  • Headquarters:
    Singapore
  • Related companies:
  • Parent website:
  • Website:

Company assessment: APP China Group Ltd – July 2019

SPOTT assesses companies against over 100 indicators across ten categories. Click on the icons or bars below to expand each category for further details, scoring and links to reports and sources.

Assessment date:

Total: 33.6% 39 / 116
  • Sustainability policy and leadership Sustainability policy and leadership 4 / 9 44.4%
    • Companies should publish sustainability policies or similar commitments covering their entire supply chain — including third party suppliers — implemented and enforced through high-level leadership that engages with wider industry schemes.

    • No
      0 / 1
      Source

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

      The company states in its sustainability report that it has a Forest Operation Policy and an Environmental Guidance Policy. However, these policies could not be identified on the company's website

    • No
      0 / 1
      No source

      2. Sustainability policy or commitment applies to all sourcing?

    • Yes
      1 / 1
      Source

      3. High-level position of responsibility for sustainability?

      The company's Sustainable Development and Corporate Social Responsibility Committee is chaired by the senior executive vice president

    • n/a
      -
      No source

      4. One or more board members have responsibility for sustainability?

      This indicator is disabled as the company is not publicly listed

    • n/a
      -
      No source

      5. Percentage or number of women board members?

      This indicator is disabled as the company is not publicly listed

    • No
      0 / 1
      No source

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

    • Yes
      1 / 1
      Source

      7. Sustainability report published within last two years?

      2,017

    • Yes
      1 / 1
      Source

      8. Member of multiple industry schemes or other external initiatives to improve forest management or transparency?

      APP Group is a member of TFT, TFA 2020, GRI, HCSA, HCVRN, Natural Capital Coalition

    • Yes
      1 / 1
      Source

      9. Activities with government, NGOs or academic institutions to improve the sustainability of forest products?

      United Nations Global Compact China, a regional network dedicated to promote the sustainable development of Chinese enterprises

    • No
      0 / 1
      No source

      10. Climate risks assessment available?

    • No
      0 / 1
      No source

      11. Natural capital assessment available?

  • Landbank, mills and traceability Landbank, mills and traceability 1 / 19 5.3%
    • Companies should publicly report figures on their total landbank and details of different areas under their management. They should also disclose maps of their forest management units and provide forest management plans, as well as details on mills.

    • No
      0 / 1
      Source

      12. Lists countries and operations?

      Limited information available. Operations focused on the Yangtze River and Pearl River Delta regions

    • n/a
      -
      No source

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

      This indicator is disabled as the company's reporting broadly suggests that it only produces wood/wood fibre from plantation forests. Please note that ZSL has been unable to confirm this

    • Yes
      1 / 1
      Source

      14. Total area of forest plantation (ha)?

      288,208

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      17. Conservation set-aside and/or HCV area (ha)?

    • n/a
      -
      No source

      18. Area of Intact Forest Landscape (ha)?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't have any intact forest landscapes within its landbank. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      Source

      19. Number of Forest Management Units (FMUs)?

      The company only states it has over 20 plantation farms and this information is undated

    • No
      0 / 1
      No source

      20. Maps of forest management units (FMUs)?

    • No
      0 / 1
      Source

      21. Forest management plans available for all FMUs?

      The company has committed to compile and implement forest management plans (2012-13 Sustainability Report). However, these FMPs could not be located

    • No
      0 / 1
      No source

      22. Monitoring of forest management plan implementation?

    • n/a
      -
      No source

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

      This indicator is disabled as the company's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

    • n/a
      -
      No source

      24. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

    • n/a
      -
      No source

      25. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      Source

      26. Number of company owned pulp and paper mills?

      The company reports different figures for the same period that are contradictory (nine / over thirty)

    • No
      0 / 1
      No source

      27. Maps or addresses of company owned pulp and paper mills?

    • n/a
      -
      No source

      28. Number of company owned sawmills?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own sawmills. Please note that ZSL has been unable to confirm this

    • n/a
      -
      No source

      29. Maps or addresses of company owned sawmills?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own sawmills. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      No source

      30. Number of supplier mills?

    • No
      0 / 1
      No source

      31. Maps or addresses of supplier mills?

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      33. Procedures to trace raw materials to FMU level?

    • No
      0 / 2
      Source

      34. Percentage of supply traceable to country level (above 80%)?

      PEFC CoC-certified pulp procured accounts for 17% of all pulp purchased and PEFC CoC-certified wood fibre accounts for 16.9% of all wood fibre purchased

    • No
      0 / 2
      Source

      35. Percentage of supply traceable to FMU level (above 75%)?

      PEFC CoC-certified pulp procured accounts for 17% of all pulp purchased and PEFC CoC-certified wood fibre accounts for 16.9% of all wood fibre purchased

  • Deforestation and biodiversity Deforestation and biodiversity 6 / 10 60%
    • Companies should commit to address deforestation and to set aside areas for conservation. They should report on any activities to manage or restore habitat in their conservation areas, or monitor deforestation in their supply chains. They should also provide evidence of biodiversity conservation and species or habitat management.

    • Yes
      1 / 1
      Source

      36. Commitment to zero conversion of natural forest?

      The company and its suppliers will only develop areas that are not forested, as identified through independent HCV and HCS assessments. This policy became effective on February 1st 2013

    • Yes
      1 / 1
      Source

      37. Zero conversion commitment applies to all sourcing?

    • n/a
      -
      No source

      38. Commitment to minimise the impact of logging roads?

      This indicator is disabled as the company's reporting broadly suggests that it only produces wood/wood fibre from plantation forests. Please note that ZSL has been unable to confirm this

    • Partial
      0.5 / 1
      Source

      39. Commitment to protect forest areas from illegal activities?

      The company commits to eliminate illegal logging. No references to wider forms of illegality could be found

    • No
      0 / 1
      No source

      40. Evidence of monitoring deforestation?

    • No
      0 / 1
      No source

      41. Amount of deforestation recorded?

    • Yes
      1 / 1
      Source

      42. Commitment to biodiversity conservation?

    • Yes
      1 / 1
      Source

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

      Compiled the Inventory of Protected State-level Animals and Plants in Hainan to assist employees and contractors in protection efforts. To protect the natural vegetation in mountainous areas, the company sets aside 10-metre buffer zones and plans the composition of tree species according to local conditions

    • No
      0 / 1
      No source

      44. Implementing a landscape-level approach to biodiversity conservation?

    • Partial
      0.5 / 1
      Source

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

      Species have been identified but not classified according to an appropriate system. The inventory also only covers species in Hainan

    • n/a
      -
      No source

      46. Commitment to sustainably manage the use of non-timber forest products (NTFPs)?

      This indicator is disabled as the company's reporting broadly suggests that it only produces wood/wood fibre from plantation forests. Please note that ZSL has been unable to confirm this

    • Yes
      1 / 1
      Source

      47. Commitment not to use genetically modified organisms?

      The company has made a commitment to not use transgenic tree species

  • HCV, HCS and impact assessments HCV, HCS and impact assessments 2.5 / 8 31.3%
    • Companies should commit to the High Conservation Value (HCV) and High Carbon Stock (HCS) approaches, and to conduct social and environmental impact assessments (SEIA). They should develop and publish summaries of assessments and monitoring and management plans.

    • Yes
      1 / 1
      Source

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

      The company will only develop areas that are not forested, as identified through independent HCV and HCS assessments

    • Yes
      1 / 1
      Source

      49. HCV commitment applies to all sourcing?

    • n/a
      -
      No source

      50. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?

      This indicator is disabled until sufficient number of HCV ALS licensed assessors are available for the location where the company operates

    • No
      0 / 1
      No source

      51. High Conservation Value (HCV) assessments available?

    • No
      0 / 1
      No source

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

    • Partial
      0.5 / 1
      Source

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

      The company will only develop areas that are not forested, as identified through independent HCV and HCS assessments. It does not specify whether it commits to the HCS Approach

    • No
      0 / 1
      No source

      54. High Carbon Stock (HCS) assessments available?

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

      56. Social and environmental impact assessments (SEIAs) available?

    • n/a
      -
      No source

      57. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

  • Water, chemical and waste management Water, chemical and waste management 4 / 12 33.3%
    • Companies should commit to protect peatland and undertake best management practices for soils and peat, as well as commit to reduced impact logging. They should also have policies on zero burning and to reduce their greenhouse gas (GHG) emissions. Companies should report their GHG emissions, as well as details on any fires that occurred in or around their estates, along with evidence for managing and monitoring fires.

    • No
      0 / 1
      Source

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

      The company only has a general commitment to "minimise the emission of pollutants, including COD and BOD"

    • Yes
      1 / 1
      Source

      73. Progress towards commitment on water quality (BOD and COD)?

      The company reports 0.26 kg of COD emission per ton of paper produced (national standard limit is 1.6 kg) and 1.99 kg of COD emissions per ton of pulp produced (national standard limit is 5 kg) in 2017

    • No
      0 / 1
      No source

      74. Commitment to protection of natural waterways through buffer zones?

    • Yes
      1 / 1
      Source

      75. Evidence of treatment of pulp and paper mill effluent?

    • n/a
      -
      No source

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

      This indicator is disabled as the company's reporting broadly suggests that it doesn't own sawmills. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      Source

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

      The company only has a general commitment to reducing water use in some mills through the UNGC 'Water Mandate', and has reduction targets in place for its mills. However, it does not disclose a time-bound target for improving water quality

    • Partial
      0.5 / 1
      Source

      78. Progress towards commitment on water use intensity?

      124,417,000 - The company reports figures on water use but not as water use intensity. The company used a total of 124,417,000 tons of water in 2016 compared to 118,173,907 tons in 2017

    • No
      0 / 1
      No source

      79. Commitment to eliminate chlorine and chlorine compounds for bleaching?

    • Partial
      0.5 / 1
      Source

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

      The company states an intention to reduce the impact and use of "dangerous chemicals" and herbicides in its operations, but does not have a time-bound commitment

    • Yes
      1 / 1
      Source

      81. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

    • No
      0 / 1
      No source

      82. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

    • No
      0 / 1
      No source

      83. Integrated Pest Management (IPM) approach?

    • No
      0 / 1
      No source

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

  • Soils, fire and GHGs Soils, fire and GHGs 1.5 / 10 15%
    • Companies should commit to managing water use and water quality, providing evidence through time-bound reduction plans, policies on toxic chemical use, waste management and treatment of wastewater and mill effluents.

    • No
      0 / 1
      Source

      58. Commitment to best management practices for soils and/or peat?

      The company commits only to reduce soil erosion. It reports that it has no plantation operations on peatland

    • n/a
      -
      No source

      59. Commitment to reduced impact logging?

      This indicator is disabled as the company's reporting broadly suggests that it only produces wood/wood fibre from plantation forests. Please note that ZSL has been unable to confirm this

    • n/a
      -
      No source

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

      This indicator is disabled as the company's reporting broadly suggests that it doesn't have landbank on peat. Please note that ZSL has been unable to confirm this

    • n/a
      -
      No source

      61. Commitment on peatland planting applies to all sourcing?

      This indicator is disabled as the company's reporting broadly suggests that it doesn't have suppliers with landbank on peat. Please note that ZSL has been unable to confirm this

    • n/a
      -
      No source

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

      This indicator is disabled as the company's reporting broadly suggests that it doesn't have landbank on peat. Please note that ZSL has been unable to confirm this

    • Yes
      1 / 1
      Source

      63. Evidence of best management practices for soils and/or peat?

      Provides evidence of soil management. The company does not have plantations on peat

    • No
      0 / 1
      No source

      64. Commitment to zero burning?

    • No
      0 / 1
      No source

      65. Commitment to zero burning applies to all sourcing?

    • Partial
      0.5 / 1
      Source

      66. Evidence of management and monitoring fires?

      The company states that it has strengthened its pre-warning systems for forest fires

    • No
      0 / 1
      No source

      67. Details/number of hotspots/fires in FMUs controlled by the company?

    • No
      0 / 1
      Source

      68. Time-bound commitment to reduce GHG emissions intensity?

      The company only has a vague commitment to "conserve energy, reduce emissions and practice global leading environmental standards". This commitment is not target-based or time-bound

    • No
      0 / 1
      No source

      69. Progress towards reducing GHG emission intensity?

    • No
      0 / 1
      No source

      70. Report GHG emissions from land use change?

    • No
      0 / 1
      No source

      71. Methodology used to calculate GHG emissions?

  • Community, land and labour rights Community, land and labour rights 11.5 / 22 52.3%
    • Companies should commit to respect human rights, including those of indigenous peoples and local communities, and free, prior and informed consent (FPIC). Companies should respect the rights of workers, report relevant workforce data, and address with health and safety issues.

    • Partial
      0.5 / 1
      Source

      85. Commitment to human rights, referencing the UN Declaration on Human Rights or UN Guiding Principles on Business and Human Rights?

      The company has a commitment to respect human rights, but does not refer to UN Declaration on Human Rights or UN Guiding Principles on Business and Human Rights

    • No
      0 / 1
      No source

      86. Commitment to human rights applies to all sourcing?

    • Partial
      0.5 / 1
      Source

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

      The company has a commitment to "acknowledge and respect rights of community citizens including traditional rights of ethnic minorities", but does not refer to the UN Declaration on Rights of Indigenous Peoples or ILO Indigenous and Tribal Peoples Convention

    • No
      0 / 1
      No source

      88. Commitment to respect legal and customary property rights?

    • Yes
      1 / 1
      Source

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

    • No
      0 / 1
      Source

      90. FPIC commitment applies to independent suppliers?

    • Yes
      1 / 1
      Source

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

    • No
      0 / 1
      No source

      92. Examples of local stakeholder engagement to prevent conflicts?

    • Partial
      0.5 / 1
      Source

      93. Details of process for addressing land conflicts available?

      The company states only that a conflict/dispute resolution mechanism has been introduced. No further details are available

    • No
      0 / 1
      No source

      94. Commitment to support the inclusion of women across forestry operations, including addressing barriers faced?

    • Yes
      1 / 1
      Source

      95. Commitment to provide essential community services and facilities?

    • n/a
      -
      No source

      96. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

    • Partial
      0.5 / 1
      Source

      97. Commitment to respect all workers' rights?

      The company commits to respecting labour rights, but does not specify that this commitment applies to all workers

    • Partial
      0.5 / 1
      Source

      98. Reference to Fundamental ILO Conventions?

      The company refers to all Fundamental ILO Conventions, except for No.138, on Minimum Age

    • Yes
      1 / 1
      Source

      99. Commitment to eliminate gender related discrimination with regards to employment and occupation?

    • n/a
      -
      No source

      100. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      Source

      101. Percentage or number of temporary employees?

    • Yes
      1 / 1
      Source

      102. Percentage or number of women employees?

      27.44%

    • Partial
      0.5 / 1
      Source

      103. Payment of minimum wage?

      The company states that it pays its employees above the minimum wage, but no evidence is provided

    • No
      0 / 1
      No source

      104. Reporting of salary by gender?

    • Partial
      0.5 / 1
      Source

      105. Commitment to address occupational health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work?

      The company has a commitment to health and safety, but does not reference the ILO Code of Practice on Safety and Health in Forestry Work

    • Yes
      1 / 1
      Source

      106. Time lost due to work-based injuries?

      1,090.55 - Hours lost per million working hours

    • Yes
      1 / 1
      Source

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

      1

    • Yes
      1 / 1
      Source

      108. Provision of personal protective equipment and related training?

  • Certification standards Certification standards 4 / 14 28.6%
    • Companies should be certified by credible certification standards, or have time-bound commitments to achieve 100% certification of forest management units. They should also ensure that their supply is verified as being in legal compliance and commit to sourcing certified wood/wood fibre.

    • No
      0 / 1
      No source

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

    • No
      0 / 1
      No source

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

    • Yes
      1 / 1
      Source

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

      254,660 (88.36%)

    • No
      0 / 1
      Source

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

      16.9%

    • No
      0 / 1
      No source

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

    • Yes
      1 / 1
      Source

      114. Commitment to source only wood/wood fibre that meets FSC Controlled Wood requirements?

    • No
      0 / 2
      No source

      115. Percentage area (ha) FSC FM certified?

    • No
      0 / 2
      No source

      116. Percentage of wood/wood fibre supply from outgrower scheme and/or independent suppliers that is FSC FM certified?

    • No
      0 / 2
      No source

      117. Percentage of all wood/wood fibre supply traded/processed that are FSC certified (above 75%)?

    • Yes
      2 / 2
      Source

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

      254,660 (88.36%)

  • Smallholders and suppliers Smallholders and suppliers 2.5 / 6 41.7%
    • Companies should report details of any programmes or schemes to support outgrower scheme smallholders, as well as criteria to assess suppliers on compliance with company policies, and in what cases suppliers should be suspended or excluded due to non-compliance.

    • No
      0 / 1
      No source

      119. Programme to support outgrower scheme smallholders?

    • No
      0 / 1
      No source

      120. Percentage of outgrower scheme smallholders involved in programme?

    • Yes
      1 / 1
      Source

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

    • Partial
      0.5 / 1
      Source

      122. The company has a Due Diligence System (DDS)?

      The company's Due Diligence System appears to only cover Hainan Jinhai Pulp & Paper

    • Yes
      1 / 1
      Source

      123. Suspension or exclusion criteria for suppliers?

      The company states that it will withdraw from 'all purchases and other agreements with any suppliers' that do not comply with its HCV, HCS, and natural forest protection commitments

    • No
      0 / 1
      No source

      124. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

  • Governance and grievances Governance and grievances 2 / 6 33.3%
    • Companies should operate in an ethical manner at all levels, providing accessible channels and clear procedures for both employees and external stakeholders to raise any grievance or complaint with the company, as well as allowing for whistleblowing.

    • Yes
      1 / 1
      Source

      125. Commitment to ethical conduct and prohibition of corruption?

    • n/a
      -
      No source

      126. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

    • No
      0 / 1
      No source

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

    • n/a
      -
      No source

      128. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

    • Partial
      0.5 / 1
      Source

      129. Whistleblowing procedure?

      The company has an email address to report whistleblowing. No details of the whistleblowing process could be identified

    • Partial
      0.5 / 1
      Source

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

      The company states they have a complaints and disputes mechanism, but only limited information is available on this process

    • No
      0 / 2
      No source

      131. Details of grievances disclosed?

Media monitor: APP China Group Ltd

SPOTT gathers reports and stories from global media sources, covering specific company activities related to the assessment indicator categories. ZSL does not assess the validity of these reports.

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