APRIL

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

The company has published a 'Sustainable Forest Management Policy' which covers all operations.

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

The company's 'Sustainable Forest Management Policy' applies to all suppliers.

3. High-level position of responsibility for sustainability?

Director of Sustainability and External Affairs.

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

The Executive Management Committee led by the president of the group.

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

1 - Out of six roles in the executive committee, one is a woman.

6. Percentage or number of women 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, TFA, HCVRN, and FFA.

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

The company collaborates with NGOs including partnerships with Fauna & Flora International and social NGO BIDARA on the management of the ecosystem restoration program, Restorasi Ekosistem Riau (RER). The RGE-FABI Tree Health Programme (RGEFABI THP) was established in 2018 as a collaborative venture between RGE and the Forestry and Agricultural Biotechnology Institute (FABI) at the University of Pretoria to address challenges posed by pests and diseases to the company's forestry operations. The company also has a Stakeholder Advisory Committee, Fire Free Alliance, and Independent Peat Expert Working Group for reducing negative environmental and social outcomes.

9. Sustainability report published within last two years?

The company published a Sustainability Report in 2022 covering the year 2021.

10. Reports through standardised reporting systems?

The company has prepared its 2021 sustainability report in accordance with Global Reporting Initiative (GRI) Core Option and has also submitted the CDP questionnaires.

11. Climate risks assessment available?

The company has published an assessment based on the WBCSD 2020 Food, Agriculture and Forest Products TCFD Preparer Forum Report typical climate-related risks and opportunities for the Forest Products Sector guidance. However, the information reported is not externally verified.

12. Natural capital assessment available?

13. Lists countries and operations?

Indonesia: plantations and production facilities.

14. Lists countries sourcing from?

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

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

1046890 - The company reports it is responsible for managing a total of 1,046,894 ha of land concessions, with 447,984 ha of plantations, 33,795 ha of livelihood plantations, and 360,200 ha of conservation or restoration, and the remainder for community and other uses.

16. 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.

17. Total area of forest plantation (ha)?

447984 - The company reports it has 447,984 ha area of the plantation, including the area of its supply partners. Data as of 2021.

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

33795 - The company reports it has a total 33,795 ha plantation area within the outgrower scheme as of December 2021.

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

0 - The company reports that it completed the establishment of plantations in its concessions in 2014 and since then did not develop new areas.

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

360200 - The company reports it has 360,200 ha of conservation and restoration area.

21. 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.

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)?

The georeferenced maps of company FMUs are available on GFW as well as on the company's sustainability dashboard.

24. Forest management plans available for all FMUs?

25. Monitoring of forest management plan implementation available?

The company provides monitoring information of its sustainable forest management policy, however progress is reported as a summary and not specific to each of the company's FMUs.

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 doesn't operate in a geography 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 doesn't operate in a geography 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 doesn't operate in a geography currently covered by Open Timber Portal.

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

The company has published the names and geo-referenced locations of all third-party supplying Forest Management Units on its sustainability dashboard.

30. Number of company owned sawmills?

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

31. Names and locations of company owned sawmills?

This indicator is disabled as the company reports that it does not own 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 name and location of the company's pulp and paper mill is available on the company 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 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 reports it has received a total wood supply of 11,787,483 tonnes in 2021 out of which 42.89% came from the company's own concessions, 40.95% came from supply partners, the open market suppliers provided 15.6% of the total supply, and suppliers of community forest plantations made up around 1% of its total wood supply in 2021.

36. Number of third party supplying mills?

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

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

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

The company makes this commitment through 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.

41. Procedures to trace raw materials to FMU level?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria. The company also states that it has a fibre sourcing due diligence system, but only limited details are provided.

42. Percentage of supply traceable to FMU level?

The company reports that all of its supply is covered by IFCC, PEFC, PHPL and/or SVLK certification.

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

The company has already achieved 100% third-party legality verification (SVLK 100%, PEFC 81%).

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

[Externally verified] 100% - The company has already achieved 100% third-party legality verification (SVLK).

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

All the company's supply is already third-party verified for legal compliance (SVLK, IFCC-PEFC, PHPL).

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

100% - The company states that all its supply is already third-party verified for legal compliance (SVLK, IFCC-PEFC), and its own products are also already 100% third-party legality verified (SVLK).

47. Percentage area (ha) FSC FM certified?

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

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

The company reports that it sources 100% of wood fibre from PEFC and FSC sources, however it doesn't provide a specific percentage for FSC.

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 meets PEFC Controlled wood source requirements.

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

81% - The company states that 81% 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 suppliers to zero conversion of natural forests to plantations or non-forest use, however it is not clear if this commitment applies to 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 no development of areas that are not forested, as identified through independent peer-reviewed High Conservation Value (HCV) and High Carbon Stock (HCS) assessments.

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 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 has implemented a Land Cover Change (LCC) monitoring system which is based on analysis of Landsat imagery for changes in land cover across all fibre supply concessions and field verifications. The area monitored covers one million hectares and images are analysed every 16 days. This information is externally verified by KPMG.

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

[Externally verified] The company reports that potential land cover change associated with encroachment is tracked using satellite imagery and field verified at the concession/estate level for the company and supply partners' concessions. However, the extent of the area monitored and the time frame for monitoring is not reported. This information has been externally verified in a report written by KPMG.

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

73 - The company reports 73 ha of forest loss due to encroachment in 2022. However, the total figure since the 2015 cut-off date is not available.

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

590 - The company reports 590 ha of forest loss due to encroachment in its supplier conservation areas in 2022. The amount of deforestation recorded in all operations of the suppliers since the 2015 cut-off date is not available.

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 be 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 employs an integrated production protection landscape approach as a part of its RER program.

65. Biodiversity policy?

The company commits to preserving and restoring biodiversity and has published positive biodiversity gains targets and reports on progress.

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 has identified species of conservation concern using the IUCN Red List. This has been externally verified in an assurance statement from 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 has a Restorasi Ekosistem Riau (RER) project focused on the comprehensive ecosystem restoration of ecologically important 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 states that it protects its concessions from encroachments and various forms of illegal activities.

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

The company commits to not source wood that is illegally traded, but it is unclear if this commitment requires suppliers to protect forest areas from any 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 also has various measures in place to protect forest areas which include land cover change monitoring, security patrols, community engagement, and boundary demarcation.

74. Commitment to no use of genetically modified organisms?

The company declares that no GMOs are used or are present in licensed areas or areas where research takes place under the company's direct or indirect responsibility.

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

The company and its suppliers declare that no GMOs are used or are present in licensed areas or areas where research takes place under the company's direct or indirect responsibility.

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 its FMUs on its 'HCV Assessments' webpage. The assessments are externally verified.

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

Only some of the company's HCV assessments include both management and monitoring plans.

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

The company commits to follow the HCS Approach as prescribed by the HCS Approach Steering Group.

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

The company commits its suppliers to follow the HCS Approach as prescribed by the HCS Approach Steering Group.

82. High Carbon Stock (HCS) assessments available?

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

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 reports that it only produces wood/wood fibre from natural forests.

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 doesn't operate in a geography currently covered by Open Timber Portal.

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

The company has a commitment to not develop forested peatlands, but this does not extend to non-forested peatlands, and the depth of peatland is not specified. Regarding non-forested peatlands, the company states that its Peat Expert Working Group will be used to provide inputs and recommendations on the development of non-forested peatland.

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

The company has a commitment to no new development on forested peatlands that applies to all current and future wood suppliers, as well as any future acquisitions or partnerships. However, this commitment does not extend to non-forested peatlands and depth is not mentioned.

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

244271 - The company reports 244,271 ha of its concessions on peatland. Data as of 2021.

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

[Externally verified] The company's landbank on peat has reduced from 245,145 ha in 2019 to 244,271 ha in 2021. This information is externally verified by KPMG in its latest report.

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.

95. Commitment to reduced impact logging?

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

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

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

97. Evidence of implementing reduced impact logging practices?

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

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 also uses fire detection resources from two National Aeronautics and Space Administration (NASA)-based systems, the Moderate Resolution Imaging Spectroradiometer (Modis) and National Oceanic and Atmospheric Administration (NOAA) monitoring technologies.

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

0 (0%) - The company reports zero fire incidents inside its concession area in 2021.

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

4 - The company reports 4 fire incidents in supply partners' concession areas in 2021.

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

The company commits to reducing GHG emissions intensity per product by 25% by 2030 from the 2019 baseline. The target includes scope 1 and scope 3 emissions.

104. GHG emissions intensity?

The company reports emissions intensity as 0.5 MTCO2e/t in 2021. 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 produces wood/wood fibre from plantations.

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

107. Progress towards commitment to reduce GHG emissions intensity?

Scope 1 emissions intensity for mills has decreased from 0.62 MTCO2e/t in 2019, to 0.6 in 2020 and 0.5 in 2021. However, the information reported is not externally verified.

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 reports a commitment of 25% less water usage per tonne of product by 2030.

110. Water use intensity?

79.1 - The company reports a water consumption of 79.1 million m3 in 2020. However, the figure reported is not intensity-based and is over two years old.

111. Progress towards commitment on water use intensity?

The company reports water consumption over years in million m3 (80.4 in 2016, 71.5 in 2017, 72.4 in 2018, 74.3 in 2019, and 79.1 in 2020). However, the figures reported are not intensity-based, and water use is not improving. Also, the information reported is over two years old.

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

The company commits to be within local legal limits for both BOD and COD and the reported figures show this target is already met.

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

The company reports progress toward its commitment to water quality. BOD (kg/adt) is reported as 0.70 (2016), 0.64 (2017), 0.63 (2018), 0.68 (2019), 0.68 (2020), and COD (kg/adt) is reported as 5.45 (2016), 5.54 (2017), 5.93 (2018), 6.39 (2019), 7.28 (2020). All the figures reported are below the regulatory threshold. However, the information reported is over two years old.

114. Treatment of pulp and paper mill effluent?

[Externally verified] The company provides several examples of wastewater treatment in its operations. Information has been externally assured by KPMG.

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

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

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

The company mentions water recycling but gives no detail on where this is implemented.

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?

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's own reporting only mentions that it implements buffer zone specifications of watercourses and riparian zones. However, no details on implementation are reported.

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 has reduced chlorine dioxide use by 4.2% from 2019 to 2021.

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 publishes a list of chemicals used in forestry operations, however it only includes pesticides.

127. Implementation of commitment to minimise inorganic fertiliser usage?

The company states that insecticide application was reduced in plantations by 27% between 2020 and 2021 and a reduction in pesticides applied in the nursery by 23% per 1,000,000 plants produced between 2019 and 2021. This is due to the implementation of an IPM strategy. However, the information reported is not externally verified.

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 percentage of the company landbank certified by PEFC. The company reports that it implements an integrated pest management program to minimise the use of chemical pesticides, however, its own reporting is not externally verified.

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 on multiple dimensions of its waste management system, however, the information reported is not externally verified.

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 ?

In 2021, the company conducted human rights training for 35 senior managers and reports that it is developing a Human Rights Due Diligence framework with external experts that will identify, measure, report, and remediate human rights issues. The framework will be finalised in 2022. However, the information reported is not externally verified.

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

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

134. Commitment to indigenous 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 commits its suppliers to respect the rights of indigenous peoples and rural communities, however, does not reference the UN Declaration/ILO Convention. A policy referencing the UN Declaration on the Rights of Indigenous Peoples does not clearly commit suppliers to respect the Declaration.

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. In addition, the company 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 reports that an FPIC process will be conducted prior to commencing new development or expansion of its activities that may potentially affect the rights holders following the procedure outlined in the company's FPIC SOP. However, limited details are provided.

140. Examples of local stakeholder engagement to prevent conflicts?

The company reports it conducts a consultation forum with local communities where they can be heard and share any concerns, and that its Social Capital Department engages directly with local communities to prioritise the activities for the year. The company also conducts stakeholder consultations on an annual basis. However, the information reported is not externally verified.

141. Details of process for addressing land conflicts available?

The company reports it actively works to resolve land claims through Land Dispute Resolution, however, limited details are provided on the process.

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

The company provides multiple examples of steps to support the inclusion of women across forestry operations. However, the information reported is over two years old now and 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 doesn't operate in a geography 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 produces wood/wood fibre from plantations.

145. Commitment to provide essential community services and facilities ?

The company has a commitment to provide essential community services and facilities.

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

The company provides multiple examples of providing essential community services and facilities such as supporting infrastructure projects, education, healthcare, and support to businesses and farmers. Information has been externally verified in a report written 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 doesn't operate in a geography currently covered by Open Timber Portal.

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

The company reports its commitment to respect International Labour Organization'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 respect International Labour Organization'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 54.2% participated in labour groups and employees were trained on workers rights in 2021.

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

The company reports its commitment to eliminate gender related discrimination with regards to employment.

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

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

155. Percentage or number of temporary employees?

21612 - The number of contractors as of December 2021: 21,612 (excluding suppliers' contractors).

156. Percentage or number of women employees?

5874 - The company reports 5,874 women employees across all operations (including the women contractors as well) in 2021.

157. Commitment to pay a living wage?

The company only reports a commitment to pay 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 percentage of the company landbank certified by PEFC. The company's own reporting also mentions following its Safety Golden Rules to minimise high-risk acts. This includes various daily activities such as the use of potentially hazardous equipment (e.g. chainsaws), transportation, working with heavy equipment, working at heights, and the handling of chemicals.

164. Time lost due to work-based injuries?

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

7 - The company reports that seven fatalities occurred across its forestry operations in 2021.

166. Commitment to support smallholders?

The company states that where possible, it incorporates small- and medium-sized farmers or enterprises into its supply chain, however it does not provide a clear commitment to support smallholders.

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

The company reports having a livelihood plantation program to provide welfare and economic support to smallholders. In 2021, 33,795 ha had been allocated to the program. However, this information is not externally verified.

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

The company only reports that it has allocated 33,795 ha of land to its livelihood plantation program in 2021. However, the number of smallholders covered by this program in 2021 is not reported.

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

[Externally verified] The company reports it sourced from one new supplier (100%) in 2021 for which the supplier due diligence process was completed prior to the first wood delivery. Existing suppliers are subjected to ongoing due diligence reviews, however, the figures on the number or percentage of suppliers for which the due diligence process was completed in 2021 apart from new suppliers, are not reported. This information is externally verified and published in a KPMG report.

171. Suspension or exclusion criteria for suppliers?

The company reports that the suppliers that do not comply with or are in violation of the company's SFMP 2.0 commitments through direct or indirect involvement are given 30 days of time to work on a Corrective Action Plan, listing the steps and providing a timeline to remedy the identified unacceptable activities.

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 be in compliance with sustainable timber and pulp sourcing commitments.

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

The company reports that 100% of its fibre suppliers are subject to a due diligence process prior to and during the contract term to ensure their compliance with the company's SFMP 2.0. However, none of this information is externally verified.

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the 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 the prohibition of corruption.

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

[Externally verified] The company reports that it provides training courses for employees that include business ethics and that it has a confidential system for anyone to report misconduct, malpractice or fraud.

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 doesn't operate in a geography 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 doesn't operate in a geography currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company reports that it has a whistleblowing hotline and email, and that whistleblower identity is protected. A description of the steps taken are also reported.

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

The company has established a grievance mechanism with resolution procedures that is accessible and open to all stakeholders, internal and external.

182. Details of complaints and grievances disclosed?

The company reports for each complaint: the date, a reference number, a description of the issue raised, who the complainant is (unless confidential), the steps taken, and the status.