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?

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 has a responsibility for sustainability.

5. Reports gender balance of senior management team?

1 - The company reports having one female member on its executive committee.

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, TFA, HCVRN, and FFA.

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

The company partners with Fauna & Flora International (FFI) to enhance its biodiversity assessment and protection practices. Additionally, it collaborates with Bidara to implement community empowerment programs aimed at fostering economic independence among villages and communities. Further collaborations include the RGE-FABI Tree Health Program to tackle challenges related to pests and diseases in forestry operations. Moreover, the company establishes a Stakeholder Advisory Committee, engages with the Fire Free Alliance, and convenes an Independent Peat Expert Working Group to mitigate adverse environmental and social impacts.

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2022.

10. Reports through standardised reporting systems?

The company's Sustainability Report 2022 has been prepared in accordance with GRI standards- core option and has submitted a CDP questionnaire.

11. Climate risks assessment available?

The company has conducted an assessment of climate-related risks and opportunities. However, this information 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 source wood/wood fibre from third-party suppliers.

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

1045560 - The company reports the total land area managed/controlled for forestry of 1,045,557 ha.

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)?

454045 - The company reports the total area of forest plantations as 454,045 ha.

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

42353 - The company reports that it has an area of plantation forest within out-grower schemes as 42,353 ha.

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

0 - The company completed the establishment of plantations in its concessions in 2014 and has since maintained existing areas without further expansion.

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

361231 - The company reports that it has 361,231 ha of conservation and restoration area.

21. Area of Intact Forest Landscape (ha)?

This indicator is disabled as the company reports that it is not a producer with Intact Forest Landscape (IFL) 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)?

Maps for all of the company's FMUs are available on Global Forest Watch.

24. Forest management plans available for all FMUs?

25. Monitoring of forest management plan implementation available?

The company provides monitoring information on its sustainable forest management policy. However, it is unclear if it covers all 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 does not operate 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 operate 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 operate in a country currently covered by Open Timber Portal.

29. Maps of all third-party supplying FMUs?

The company provides virtual maps for its suppliers, however no coordinates or geo-referenced information is provided.

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 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 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?

In 2022, the company recorded a total wood supply of 11,964,368 tonnes. This supply comprised 38.46% from the company's own concessions, 46.42% from supply partners, 14.84% from open market suppliers, and approximately 0.28% from community forest plantation suppliers.

36. Number of third party supplying mills?

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

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

This indicator is disabled as the company reports it does not directly source from third-party 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 it does not directly source from third-party 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?

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 full 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 92%).

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

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?

1.2% - The company reports that it sources 1.2% of pulp 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)?

92% - The company reports that 92% 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 unclear 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 in High Conservation Value (HCV), High Carbon Stock (HCS) and peatland areas.

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 utilises satellite imagery to track changes in land cover, ensuring the protection of forested regions within production, conservation, and restoration zones against unauthorised encroachment, settlements, and illegal activities. Additionally, it regularly collects detailed satellite images every 16 days and conducts comparisons to detect potential alterations in land cover attributed to deforestation activities. 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 is not externally verified.

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. 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.

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 2022. 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 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 progress reports.

66. Biodiversity policy applies to all suppliers?

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

The company has identified species of conservation concern such as threatened, endangered, critically endangered, vulnerable, and near threatened using the IUCN Red List.

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 protecting forest areas from illegal activities. However, it is unclear if it applies to all suppliers.

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

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

The company's HCV assessments include summaries of management and monitoring plans. However, only some reports are externally verified.

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 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?

The company has published three social impact assessment (SIA) summary reports on its webpage.

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 operate in a country 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)?

249093 - The company reports 249,093 ha of its concessions on peatland. Data as of 2022.

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 also implements management practices to conserve soils. However, this information is not externally verified.

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 OR only sources from plantations.

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. Additionally, the company uses fire detection resources and other complementary technologies to enhance the spotting capabilities of its fire monitoring towers and closed-circuit television camera towers situated around the plantation forests.

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

0 (0%) - The company reported zero fire incidents inside its concession area in 2022.

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

2 - The company reported two fire incidents in supply partners' concession areas in 2022.

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

The company commits to reduce GHG emissions intensity by 25% by 2030.

104. GHG emissions intensity?

The company reports emissions intensity as 0.47 MTCO2e/t in 2022. 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)?

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports that the scope 1 emissions intensity for mills has decreased from 0.6183 MTCO2e/t in 2020, to 0.5022 in 2021, and 0.4701 in 2022. However, this information 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 commits to reduce water intensity by 25% by the year 2030.

110. Water use intensity?

28 - The company reports the water intensity as 28 m3/T. Data as of 2022.

111. Progress towards commitment on water use intensity?

The company reports water consumption figures but not consumption intensity and figures are not improving.

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

The company commits to maintain BOD and COD levels within legal limits.

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

The company reports water quality data as of 2022 and COD/BOD levels are within legal limits.

114. Treatment of pulp and paper mill effluent?

The company explicitly reports the treatment of pulp and paper mill effluent. However, this information is not externally verified.

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 OR only trades wood/wood fibre.

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

The company mentions water recycling without providing specific information about its implementation.

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 also 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 reports that it uses elemental chlorine-free technology. However, this information is not externally verified.

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 reports that insecticide application was reduced in plantations by 27% between 2020 and 2021. This is due to the implementation of an IPM strategy. However, this information 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 percent of company landbank certified by PEFC. The company reports that it implements an integrated pest management program to minimise the use of chemical pesticides. However, this information 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, this information 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 ?

The company conducts human rights awareness training and regularly reviews and progresses reports regarding the identification, mitigation, and remediation of its actual and potential human rights impacts. Additionally, it reports the establishment of a multifunctional team tasked with driving the implementation of its human rights due diligence process. However, this information is not externally verified.

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 commits its suppliers to respect the rights of Indigenous peoples and rural communities, however, it 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 conducts annual community engagement sessions to listen to feedback and address concerns. Additionally, the Social Capital Department directly engages with local communities. However, this information is not externally verified.

141. Details of process for addressing land conflicts available?

The company reports that 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 limited examples of steps to support the inclusion of women across forestry operations. However, this 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 operate 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?

In 2022, the company's efforts reached 88 villages through its livelihood-related program, 131 villages through its health program, and 110 villages through its education program. Additionally, it contributes to the Social Infrastructure Development Project in Riau, spanning 57 villages and facilitating the construction of schools, mosques, village centers, sports arenas, community halls, roads, and other associated facilities. However, this information is not externally verified.

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 operate 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 respect the 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 that 46% of its employees participated in labor groups, and 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 suppliers to commit to ILO Convention 111 Discrimination. However, the commitment is unclear as the company only states that it encourages suppliers.

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

The company reports that it has established a female forum which hosts talks on issues relating to gender discrimination and engages with the company's paper business unit. The company also states that it has undertaken training on gender equality and has launched a month campaign to prevent gender-based harassment within the company's operation areas. This information is not externally verified.

155. Percentage or number of temporary employees?

21915 - The company reports that it has 21,915 contractor workers as of 2022.

156. Reports gender balance of employees?

6490 (18.6%) - The company reports 6,490 (18.6%) women employees across all operations (including contractors) in 2022.

157. Commitment to pay a living wage?

The company only reports a commitment to pay 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's own reporting also mentions following its safety golden rules to minimise high-risk acts.

164. Time lost due to work-based injuries?

0.62 - The company reports the total lost time injury frequency rate as 0.62.

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

7 - The company reports that seven fatalities occurred across its operations in 2022.

166. Commitment to support smallholders?

The company states that it incorporates small- and medium-sized farmers or enterprises into its supply chain where possible. 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 2022, 42,353 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 42,353 ha of land to its livelihood plantation program in 2022. However, the number of smallholders covered by this program in 2022 is not reported. This information is not externally verified.

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] The company reports that it conducts an annual due diligence process for its suppliers, covering 100% of suppliers in 2023. 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 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 reports limited information on ethical issues training to employees. However, this information 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 operate 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 operate in a country 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 (incuding both internal and external).

182. Details of complaints and grievances disclosed?

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