APRIL

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

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

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

The company has published a sustainable forestry policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has appointed a Director of Sustainability and External Affairs, who is responsible for overseeing sustainability matters.

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

The Executive Management Committee is responsible for overseeing sustainability matters.

5. Reports gender balance of senior management team?

The company reports that women comprise 10.7% of its senior management team.

6. Reports gender balance of board members?

1 - The company has one female board member.

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

[Externally verified] The company is a member of PEFC, UNGC, WBCSD, and HCVRN.

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

The company collaborates with Fauna & Flora International (FFI) to strengthen its biodiversity assessment and protection efforts. It also partners with Bidara to implement community empowerment programs that promote economic independence in local villages. Additional partnerships include working with the Wildlife Conservation Society (WCS) to combat illegal wildlife trade and with the Forest Wildlife Society (PJHS) to develop species-specific conservation management plans for tigers, pangolins, and elephants. Furthermore, the company has established a Stakeholder Advisory Committee and engages with an Independent Peat Expert Working Group to help mitigate adverse environmental and social impacts.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2024.

10. Reports through standardised reporting systems?

The company's 2023 sustainability report has been prepared in accordance with GRI 1: Foundation 2021.

11. Climate risks assessment available?

The company has carried out an assessment of climate-related risks and opportunities.

12. Natural capital assessment available?

13. Lists countries and operations?

Indonesia - plantations and production facilities.

14. Lists countries sourcing from?

The company reports it has suppliers in Indonesia, Malaysia, Vietnam, Thailand, Canada, New Zealand, and Europe. However the countries within Europe are not stated.

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

1423820 - The company reports a total of 1,423,815 ha of land managed or controlled for forestry purposes.

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

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

17. Total area of forest plantation (ha)?

607084 - The company reports a total forest plantation area of 607,084 ha in 2024.

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

45569 - The company reports a total natural forest area within outgrower schemes of 45,569 ha in 2024.

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

0 - The company reports 0 ha of undeveloped forest plantation.

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

465886 - The company reports that it has 465,886 ha of conservation and restoration area.

21. Area of Intact Forest Landscape (ha)?

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

22. Number of Forest Management Units (FMUs)?

12 - The company lists 12 concessions within PT Riau Andalan Pulp and Paper (PT RAPP), its pulp and paper operating arm.

23. Maps of forest management units (FMUs)?

Maps for all of the company's FMUs are available on Global Forest Watch. However, the data is now over two years old. The company also publishes dated virtual maps on its own website, however it is not possible to download these maps or precisely determine the coordinates of concession boundaries.

24. Forest management plans available for all FMUs?

25. Monitoring of forest management plan implementation available?

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

29. Maps of all third-party supplying FMUs?

The company provides dated digital maps for all of its suppliers, however it is not possible to download these maps or precisely determine the coordinates of concession boundaries.

30. Number of company owned sawmills?

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

31. Names and locations of company owned sawmills?

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

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

1 - The company operates one mill in Pangkalan Kerinci, Riau Province, Sumatra.

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

The company discloses the name and location of its pulp and paper mill on its website.

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

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

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

The company recorded a total wood supply of 15,435,962 tonnes in FY2024. This comprised 31% from its own concessions, 54% from supply partners, 13% from open market suppliers, and 2% from community forest plantation suppliers.

36. Number of third party supplying mills?

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

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

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

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

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

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

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

40. Percentage of supply traceable to country of harvest?

100 - The company makes this commitment through SVLK certification requirements. Full points have been awarded for this indicator on the basis that 100% of the company's wood/wood fibre supply is SVLK certified. The company also reports that 100% of the wood and fibre sourced for its pulp, paper, and viscose mill is traceable to its country of harvest. However, this information is not externally verified.

41. Procedures to trace raw materials to FMU level?

The company demonstrates this commitment through adherence to the PEFC International Chain of Custody Standard and SVLK certifications. It also states that it has a fibre sourcing due diligence system in place, however, only limited details are disclosed.

42. Percentage of supply traceable to FMU level?

The company reports that 99% of its total supply is traceable to the FMU level.

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

The company is 100% legality verified by SVLK.

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

100% - The company is 100% legality verified by SVLK.

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

The company reports that its entire supply is third-party verified for legal compliance through certifications such as SVLK and PEFC.

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

100% - The company reports that its entire supply is third-party verified for legal compliance through certifications such as SVLK, and PEFC.

47. Percentage area (ha) FSC FM certified?

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

The company reports it is currently undergoing a remedy process to be reassociated with FSC.

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

1.2% - The company reports that 1.2% of its pulp is sourced from FSC FM-certified areas.

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

The company reports a commitment to source wood/wood fibre that meet PEFC Controlled wood source requirements.

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

88.1% - The company reports that 88.10% of its concession areas are PEFC FM certified.

52. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of natural ecosystems.

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

The company commits to eliminating the conversion of natural forests into plantations or for non-forest use, however, it does not extend this commitment to the zero conversion of all natural ecosystems.

54. Commitment to zero deforestation?

The company commits to zero deforestation.

55. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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

The company defines deforestation as the development of forested areas as identified through independent peer-reviewed High Conservation Value (HCV) and High Carbon Stock (HCS) assessments and specifies any deforestation past June 2015 will not be accepted.

57. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

The company defines deforestation for suppliers as the development of forested areas as identified through independent peer-reviewed High Conservation Value (HCV) and High Carbon Stock (HCS) assessments and specifies any deforestation past June 2015 will not be accepted.

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

[Externally verified] The company uses satellite imagery to monitor changes in land cover, aiming to protect forested areas within its production, conservation, and restoration zones from unauthorised encroachment, settlements, and illegal activities. High-resolution satellite images of concessions are collected every 16 days and analysed to detect potential deforestation. This monitoring process is externally verified by KPMG. However the timeframes and extent of area monitored have not been externally verified.

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

[Externally verified] The company states that it monitors potential land cover changes from encroachment via satellite imagery and subsequently verifies these observations on the ground at both its own concessions and those of its supply partners. High-resolution satellite images of concessions are collected every 16 days and analysed to detect potential deforestation. This monitoring process is externally verified by KPMG, however the timeframes and extent of area monitored have not been externally verified.

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

107 - The company reports 107 ha of forest loss due to encroachment in the FY2023. The company reports the amount of deforestation within its own concessions and its supply partners' concessions on an annual basis but has not provided a single total figure since the 2015 cut-off date.

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

262 - The company reports 262 ha of forest loss due to encroachment in the FY2023. The company reports the amount of deforestation on an annual basis but has not provided a single total figure since the 2015 cut-off date.

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

The company commits to combat desertification, restoring degraded land and soil, including land affected by desertification, drought, and floods, and strives to achieve a land degradation-neutral world by restoring ecosystems. However, the commitment is unclear. The cut-off date beyond which deforestation will not be accepted is reported as June 2015.

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

The company commits its suppliers to restore previously degraded forests areas, the cut-off date beyond which deforestation will deemed as non-compliant is 3 June 2015. As the company states "previously degraded" it is unclear if non-compliant deforestation from 2015 onwards is restored.

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018). As the Standard does not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded. The company also adopts an integrated landscape approach as part of its RER program.

65. Biodiversity policy?

The company commits to preserving and restoring biodiversity and has published targets for achieving positive biodiversity gains, along with progress reports.

66. Biodiversity policy applies to all suppliers?

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

[Externally verified] The company reports that it has identified several species of conservation concern, as classified under the IUCN species classification system. This information is externally verified by KPMG.

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

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. The company also operates the Restorasi Ekosistem Riau (RER) project, which focuses on the comprehensive restoration of ecologically significant peat forest areas on the Kampar Peninsula.

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

The company commits to no hunting of all species in its operations.

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

71. Commitment to protect forest areas from illegal activities?

The company commits to protect the natural ecosystems and plantations under its management from illegal activities.

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

The company commits to protecting forest areas from illegal activities.

73. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. The company reports that it monitors illegal activities, including land cover changes, through satellite imaging, on-the-ground security patrols, clear demarcation of no-go areas, and ongoing engagement with local communities to support forest protection. Additionally, it deploys an emergency response team to address illegal encroachment within its concession areas.

74. Commitment to no use of genetically modified organisms?

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

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

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

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

The company commits to conduct HCV assessments.

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

The company commits all suppliers to conduct HCV assessments.

78. High Conservation Value (HCV) assessments available?

[Externally verified] The company publishes links to HCV assessments for all of its FMUs on its dashboard. Reports are externally verified by Tropenbos and LPPM.

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

[Externally verified] The company's HCV assessments include summaries of management and monitoring plans. Reports are externally verified by Tropenbos and LPPM.

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

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

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

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

82. High Carbon Stock (HCS) assessments available?

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

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

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

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

The company commits to conduct social and environmental impact assessments.

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

The company 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.

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

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

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

The company commits to not developing forested peatlands; however, this commitment does not extend to non-forested peatlands, and it does not specify the depth of peat considered. For non-forested peatlands, the company states that its Peat Expert Working Group will provide input and recommendations regarding their development.

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

The company commits to no new development on forested peatlands, and this applies to all current and future wood suppliers, as well as future acquisitions or partnerships. However, the commitment does not extend to non-forested peatlands, and it does not specify peat depth.

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

248728 - The company reports that 248,728 ha of its concessions are located on peatland. Data as of 2023.

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

[Externally verified] The company's landbank on peat (excluding conservation areas) has decreased from 249,093 ha in 2022 to 248,728 in 2023. This information is externally verified by KPMG.

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

The company commits to best management practices for soils and peat.

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

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

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

Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. The company employs minimal soil tillage and spot soil preparation techniques to reduce water runoff and has established permanent soil sample plots to monitor changes in soil fertility across rotations. Additional soil conservation practices include minimising sedimentation, establishing buffer zones, and limiting disturbances on steep slopes and areas with inadequate vegetation cover. The company also reports conducting peat-rewetting. This information is externally assured by KPMG.

95. Commitment to reduced impact logging?

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

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

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

97. Evidence of implementing reduced impact logging practices?

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

98. Commitment to zero burning?

The company commits to zero burning.

99. Commitment to zero burning applies to all suppliers?

The company commits all suppliers to zero burning.

100. Evidence of fire monitoring and management?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company reports the installation of satellite imaging and closed-circuit television systems to monitor and manage fires within its concession areas and up to three kilometres beyond their boundaries. Additionally, it implements the Fire Free Village Program (FFVP), which educates local communities on fire prevention and management.

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

0 (0%) - The company reported zero fire incidents inside its concession area in 2023.

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

0 (0%) - The company reported no fire incidents in its suppliers' operational areas in 2023.

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

The company commits to reduce GHG emissions intensity by 25% by 2030 from the 2019 baseline.

104. GHG emissions intensity?

The company reports its GHG emissions intensity as 0.486 MTCO2e per tonne in 2023. This includes scope 1 and scope 3 emissions (negligible scope 2 emissions).

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

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

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

The company reports emissions from land use change in its open market suppliers as 291,657 tCO2e in 2024.

107. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports that Scope 1 emissions intensity for its mills increased from 0.486 MTCO2e per tonne in 2023 to 0.570 MTCO2e per tonne in 2024. This information is externally verified by TÜV SÜD PSB Pte. Ltd.

108. Methodology used to calculate GHG emissions?

The company's GHG inventory follows the GHG protocol.

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

The company commits to reduce water intensity by 25% by the year 2030 compared to 2019 baseline.

110. Water use intensity?

28.72 - The company reports a water intensity of 28.72m³ per tonne. Data as of 2023.

111. Progress towards commitment on water use intensity?

[Externally verified] The company reports an increase in water consumption intensity, rising from 28.7m³/tonne in FY2023 to 28.9m³/tonne in FY2024.

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

The company commits to maintain COD levels within legal limits.

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

The company reports an increase in COD levels, from 176.58mg/L in FY2023 to 225.6 mg/L in FY2024.

114. Treatment of pulp and paper mill effluent?

The company states that it operates an integrated wastewater treatment plant with a treatment capacity of 280,000m³ per day. Additionally, it has installed a new effluent treatment facility with a capacity of 145,000m³ per day to handle wastewater from its additional fibre production line.

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

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

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

The company states that it aims to improve water use intensity through recycling, wastewater management, and by upgrading or retrofitting equipment. However, it does not disclose the proportion of its processing facilities equipped with closed-loop water treatment systems.

117. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways using buffer zones.

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

[Externally verified] 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. An assurance report conducted by KPMG reports the company is implementing buffer zones to manage erosion risk, but only limited details are provided.

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

The company commits to minimise the use of chemical fertilisers and pesticides.

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

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

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

The company reports that it does not use elemental chlorine (Cl) in its bleaching processes, opting instead for chlorine dioxide (ClO). It also notes a 5.7% reduction in chlorine dioxide consumption intensity, decreasing from 12.70kg per air-dried tonne (kg/ADt) in 2023 to 11.97 kg/ADt in 2024.

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

The company commits to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits all suppliers to not use World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company commits to not use Stockholm and Rotterdam Convention chemicals.

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

The company commits all suppliers to not use Stockholm and Rotterdam Convention chemicals.

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

The company has published a list of pesticides and inorganic fertilisers used in its forestry operations.

127. Implementation of commitment to minimise inorganic fertiliser usage?

The company reports a reduction in inorganic fertiliser usage, decreasing from 213 units/ha in 2022 to 196 units/ha in 2023.

128. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company states that it produces biological pest control agents to manage insect infestations in young eucalyptus plantations.

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

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports generating both hazardous and non-hazardous waste. Non-hazardous waste is either recycled or sent to landfill, while hazardous waste is appropriately disposed of by a licensed third-party.

130. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights.

131. Commitment to human rights applies to all suppliers?

The company commits all suppliers to the Universal Declaration of Human Rights.

132. Progress on human rights commitment ?

The company states that it delivers human rights awareness training to its employees and managers. It has also established a human rights due diligence system to support the implementation of its human rights policy and to guide the identification, management, monitoring, and reporting of actual or potential human rights impacts across its operations.

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

The company commits to the UN Declaration on the Rights of Indigenous Peoples.

134. Commitment to Indigenous Peoples' and local communities' 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. In addition, the company requires its suppliers to respect the rights of Indigenous Peoples and local communities. However, it does not explicitly reference the UN Declaration on the Rights of Indigenous Peoples or the relevant ILO Convention. While a policy mentions the UN Declaration, it does not clearly establish a commitment for suppliers to adhere to it.

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

The company commits to respect legal and customary land tenure rights.

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

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

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

The company commits to free, prior, and informed consent (FPIC).

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

The company commits its suppliers to free, prior, and informed consent (FPIC).

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

The company states that an FPIC process will be undertaken prior to any new development or expansion that could potentially impact rights holders, following the procedure outlined in its FPIC SOP. However, the disclosure provides limited details on the process.

140. Examples of local stakeholder engagement to prevent conflicts?

The company reports that it engages with local communities through one-on-one meetings and stakeholder forums. It has also established a Stakeholder Advisory Committee and carries out participatory mapping exercises as part of its land dispute resolution process.

141. Details of process for addressing land conflicts available?

The company reports details of processes for addressing land conflicts.

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

The company reports examples of supporting the inclusion of women in forestry operations, including barriers faced. However, the information is not externally verified.

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

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

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

145. Commitment to provide essential community services and facilities ?

The company commits to providing essential community services and facilities.

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

[Externally verified] In 2023, the company supported 170 villages through its livelihood program, 134 through its health initiatives, and 121 through its education program. It also contributed to the social infrastructure development project, constructing 56 roads, village offices, and public facilities for religious and community activities. Additionally, the company played a role in reducing poverty in surrounding communities. This information is externally verified by KPMG.

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

The company reports a commitment to providing business and work opportunities for local communities.

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

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

The company commits to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

The company commits its suppliers to the ILO's Declaration on Fundamental Principles and Rights at Work.

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

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company also reports that 600 newly hired employees received training on workers' rights.

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

The company commits to eliminating gender-related discrimination with regard to employment.

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

The company states that it encourages its suppliers to commit to ILO Convention 111 on discrimination. However, the commitment remains unclear, as the company only states that it encourages suppliers rather than a mandatory requirement.

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

The company has introduced an SOP on anti-sexual harassment and bullying, developed with support from the Indonesia Business Coalition for Women Empowerment (IBCWE), to educate employees and encourage the reporting of incidents. It has also established advisory teams to address reported cases of sexual harassment. However, this information is not externally verified.

155. Percentage or number of temporary employees?

14005 (53.6%) - The company reports that it has 14,005 contractor workers as of 2023.

156. Reports gender balance of employees?

7243 (18.4%) - The company reports 7,243 (18.4%) women employees across all operations (including the women contractors) in 2023.

157. Commitment to pay a living wage?

The company reports a commitment to paying at least the minimum wage.

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

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

161. Commitment to address occupational health and safety?

The company commits to addressing health and safety at work, referencing the ILO Code of Practice on Safety and Health in Forestry Work.

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

The company makes this commitment through SVLK certification requirements. Partial points have been awarded for this indicator on the basis that 100% of the company's wood/wood fibre supply is SVLK certified and the requirements do not fully meet the SPOTT indicator criteria. The company's own commitment only commits suppliers to address occupational health and safety.

163. Provision of personal protective equipment and related training?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by PEFC. The company also operates a safety academy that delivers Occupational Health and Safety (OHS) training to all workers and visitors.

164. Time lost due to work-based injuries?

0.63 - The company reports a total lost time injury frequency rate of 0.63 for the year 2024.

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

10 - The company reports a total of 10 fatalities across its operations in 2024.

166. Commitment to support smallholders?

The company states that it incorporates small- and medium-sized farmers or enterprises into its supply chain where feasible. However, it does not make a clear commitment to supporting smallholders.

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

The company reports that it supports local farmers through its agribusiness programme, which provides agricultural assistance and training on sustainable farming practices. Additionally, it supports small and medium enterprises (SMEs) through various livelihood programmes.

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

994 - The company reports supporting 994 local farmers through its agribusiness programme by providing agricultural assistance and training on sustainable farming practices. However, it does not clarify whether these farmers are outgrowers or independent smallholders.

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

The company's policy for association sets out the procedure used to assess and confirm the compliance of prospective and current suppliers.

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

[Externally verified] 100% - The company reports that it conducted an annual due diligence process covering 100% of its suppliers in 2023. This information is externally verified and published in a report by KPMG.

171. Suspension or exclusion criteria for suppliers?

The company states that suppliers found to be non-compliant with its SFMP 2.0 commitments, either directly or indirectly, are given 30 days to develop a Corrective Action Plan outlining the necessary steps and timeline to address the identified violations.

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

The company has provided time-bound action plans for suppliers to comply with sustainable timber and pulp sourcing commitments.

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

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and prohibition of corruption.

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

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

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

The company states that it provided business ethics training to 5500 employees in 2024, however, this is not externally verified.

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

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

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

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company reports that it has a whistleblowing hotline and email in place, with assurances that whistleblower identities are protected. It also provides a description of the steps taken when handling reported cases.

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

The company has established a grievance mechanism with resolution procedures that are accessible to all stakeholders.

182. Details of complaints and grievances disclosed?

The company discloses detailed information for each complaint and grievance, including the date, reference number, issue description, complainant identity (unless confidential), actions taken, and current status.