APRIL

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

The company has Sustainable Forest Management Policy 2.0 for all its operations.

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

The company has Sustainable Forest Management Policy 2.0 for both the company and its suppliers.

3. High-level position of responsibility for sustainability?

The Director of Sustainability and External Affairs is responsible for the development, execution and monitoring compliance of April's sustainability strategy.

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

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

Out of eight senior managers one is a woman, as of May 2021.

6. Percentage or number of women board members?

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, WBCSD, UNGC, TFA, HCV 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 flagship ecosystem restoration program, Restorasi Ekosistem Riau (RER). The company also has Stakeholder Advisory Committee, Fire Free Alliance, Rainforest Alliance, Independent Peat Expert Working Group for reducing negative environmental and social outcomes.

9. Sustainability report published within last two years?

Sustainability Report 2019.

10. Reports through standardised reporting systems?

The company has prepared its sustainability report in accordance with GRI standards and also submitted the CDP questionnaire.

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

The company's entire activity (Pulp& paper mill and plantation) is in Indonesia.

14. Lists countries sourcing from?

The company reports that 2% of its pulp supply is coming from external sources sourced from Sweden, Finland, and New Zealand.

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

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

16. Total area of forest plantation (ha)?

448,639 - The company has a 448,639 ha area of plantation.

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

35,305 - The company reports it has a 35,305 ha plantation area within outgrower scheme.

18. 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.

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

365,733 - The company has a 365,733 ha conservation area.

20. Area of Intact Forest Landscape (ha)?

The company only provides a static map of intact forest landscape in its Sustainability report.

21. 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.

22. Maps of forest management units (FMUs)?

The company's FMU geo-referenced maps are available on on GFW as well as on the company's Sustainability dashboard.

23. Forest management plans available for all FMUs?

24. Monitoring of forest management plan implementation available?

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

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

29. Number of company owned sawmills?

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

30. Names and locations of company owned sawmills?

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

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

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

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

Jl. Lintas Timur, Pangkalan Kerinci Kabupaten Pelalawan Riau.

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

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

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

The company sources 4,420,720 tonnes of fiber from its own plantation which is 42% of its total supply, 33% from supply partners, 23% open market suppliers, and 2% from community fiber plantation.

35. Number of third party supplying mills?

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

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

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

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

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

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

The company reports that all of its supply is covered by PEFC-FM, PEFC-CoC and/or SVLK certification. These certifications count as procedures to trace raw materials to country of harvest.

39. Percentage of supply traceable to country of harvest?

100 - The company reports that all of its supply is covered by PEFC-FM, PEFC-CoC and/or SVLK certification. These certifications count as procedures to trace raw materials to country of harvest.

40. Procedures to trace raw materials to FMU level?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's PEFC CoC certification. In addition, the details of a process to trace raw materials to FMU level are not available.

41. Percentage of supply traceable to FMU level?

The company reports that all of its supply is covered by PEFC-FM, PEFC-CoC and/or SVLK certification.

42. 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 88%).

43. 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).

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

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

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

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

46. Percentage area (ha) FSC FM certified?

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

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

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

The company has provided the commitment to source wood/wood fiber from PEFC Controlled wood source requirement.

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

87.71% - The company state that its 87.71% concession areas are PEFC certified.

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

The company and its suppliers commit to "only develop areas that are not forested, as identified through independent peer-reviewed High Conservation Value (HCV) and High Carbon Stock (HCS) assessments".

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

The company and its suppliers commit to "only develop areas that are not forested, as identified through independent peer-reviewed High Conservation Value (HCV) and High Carbon Stock (HCS) assessments".

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

The company and its fiber suppliers commit to no deforestation and no new development on peatland, to only develop areas that are not forested as identified through High Conservation Value (HCV) and High Carbon Stock (HCS) assessments. Cut-off date- 31 December 2015.

54. Evidence of monitoring deforestation?

[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 fiber supply concessions and field verifications. The area monitored covers one million hectares and images are analysed every 16 days. However, only some of the information has been externally verified in a report written by KPMG.

55. Evidence of monitoring deforestation in supplier operations?

[Externally verified] The company state that all its suppliers are subject to compliance monitoring. This includes land cover change (LCC) monitoring and internal SFMP 2.0 compliance audits, with a specified time-frame. However, only some of this information is externally verified in a report written by KPMG.

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

2 - The company reports 2 ha of forest loss due to encroachment in its conservation areas in 2019.

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

85 - The company reports 85 ha of forest loss due to encroachment in its supplier conservation areas in 2019. It is unclear if this figure represents forest loss across all supplier operational areas (e.g. areas outside of conservation set-asides).

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

The company commits 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.

59. Commitment to restoration of non-compliant deforestation/conversion applies to all suppliers?

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.

60. Implementing a landscape or jurisdictional level approach?

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

61. Commitment to biodiversity conservation?

The company has provided an explicit commitment to biodiversity conservation.

62. Commitment to biodiversity conservation applies to all suppliers?

The company has a commitment to biodiversity conservation that applies to all its suppliers.

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

The company has reported 797 species of plants and animals recorded in the RER area, 57 are of conservation concern listed on the IUCN Red List, with 36 listed as being vulnerable, 13 endangered, and 8 critically endangered. There are also 114 species on the CITES list and 106 species noted by the Government of Indonesia as being of conservation concern.

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

Restorasi Ekosistem Riau (RER) project focused on the comprehensive ecosystem restoration of ecologically important peat forest areas on the Kampar Peninsula. Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume.

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

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

67. Commitment to protect forest areas from illegal activities?

The company states that it protects its concessions from encroachments and various forms of illegal activities.

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

69. Evidence of protecting forest areas from illegal activities?

The company has provided multiple examples of protecting forest areas from illegal activities. Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume. The company also states that its conservation teams carry out regular patrols across concession areas to identify illegal activities.

70. Commitment to no use of genetically modified organisms?

The company is committed to no use of genetically modified organisms in any of its research programs and initiatives.

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

The company has an explicit commitment to no use of genetically modified organisms applies to all its suppliers.

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

The company has an explicit commitment to conduct High conservation value assessments.

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

The company has a commitment to conduct High Conservation Value assessments that apply to all suppliers.

74. High Conservation Value (HCV) assessments available?

The company publishes links to HCV assessments for all its FMUs on its "HCV Assessments" webpage. However, these have not been externally verified.

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

The company's HCV assessments include management plans. However, these have not been externally verified, and do not include monitoring plans.

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

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

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

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

78. High Carbon Stock (HCS) assessments available?

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

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

The company only commits to conduct Environmental Impact assessments (Amdal) in its latest Sustainability Report.

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

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

Three social impact assessment summaries are available, however management and monitoring plans are not, and assessments do not cover environmental impact.

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

The company has a commitment not to develop forested peatlands, but this does not extend to 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.

84. 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. This commitment does not extend to non-forested peatlands.

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

448,663 - The company reports two very different figures for the same period: 245,145 ha planted area on peat in its sustainability report 2019, and 448,663 ha planted area on peat on its website. These figures include both the company's and its suppliers' operations.

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

The figures reported by the company in its sustainability reports (plantation on peatland is 242,465 ha in 2018 and 245,245 ha in 2019) indicate an increase in the area planted on peat.

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

The company has published this commitment.

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

The company states its commitment to best management practices for peat which applies to its suppliers as well. No equivalent commitment could be identified for other soil types.

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

The company has only provided evidence of best management practices for the peat and has commissioned an Independent Peat Expert Working Group. No best management practices could be identified for soils.

90. Commitment to reduced impact logging?

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

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

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

92. Evidence of implementing reduced impact logging practices?

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

93. Commitment to zero burning?

The company has a clear commitment to no burning.

94. Commitment to zero burning applies to all suppliers?

The company has a commitment to no burning that applies to all its suppliers.

95. Evidence of fire monitoring and management?

The company has provided multiple examples of fire monitoring and management in its sustainability report. Points for external verification have been awarded on the basis of the company's PEFC certification.

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

2 - The company reports 2 fire incidents inside its concession area in 2019.

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

8 - The company reports 8 fire incidents inside its supply partner's concession area in 2019.

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

The company has a commitment to reduce GHG emissions intensity per product 25% by 2030.

99. GHG emissions intensity?

The company reports GHG emission Intensity for Pulp and Paper production as 0.55 tCO2e/adt pulp and 0.89 tCO2e/tonne paper respectively in 2019. These figures only cover industrial operations, but GHG emissions from forestry operations are not disclosed.

100. GHG emissions from land use change?

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

101. Progress towards commitment to reduce GHG emissions intensity?

Change in GHG Intensity (in tCO2 e) is reported: 1,614,853 (2017) 1,650,893 (2018) 2,094,481 (2019). However, it has increased over time. Figures for 2020 has been reported but no metrics are assigned to figures, therefore they haven't been counted in scoring.

102. Methodology used to calculate GHG emissions?

International Council of Forest and Paper Associations (ICFPA), the National Council for Air and Stream Improvement (NCASI) and the WRI/WBCSD GHG Protocol.

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

The company has a commitment to consume less water through mill usage than comparable operations and to continually increase water-use efficiency. This commitment has no specific target for water use intensity and is not time-bound.

104. Water use intensity?

26.3 - The company reports a water consumption of 26.3 m3/adt.

105. Progress towards commitment on water use intensity?

The company reports water use intensity over time (24.0 m3/adt in 2019, 25.7 m3/adt in 2018, and 26.3 m3/adt in 2019). However, it is not improving.

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

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

The company reports progress towards its commitment on water quality. BOD in treated waste water: 0.64(2017), 0.63(2018), 0.68 (2019). COD in treated waste water: 5.54(2017), 5.93(2018), 6.93(2019).

108. Treatment of pulp and paper mill effluent?

The company provides several examples of wastewater treatment in its operations, however this is not externally verified.

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

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

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

111. Commitment to protect natural waterways through buffer zones?

The company has provided the commitment that covers the provision of buffer zones in conservation areas only.

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

The company only provides limited details on the use of plantation buffer zones referring to conservation areas.

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

The company has a Pesticide and Other Hazardous Materials use Policy.

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

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

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

The company has a commitment to not use WHO 1A and 1B pesticide.

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

The company has published this commitment.

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

The company has a commitment to no use of chemicals listed under the Stockholm and Rotterdam Convention.

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

The company has published this commitment.

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

121. Implementation of commitment to reduce chemical usage?

122. Integrated Pest Management (IPM) approach?

The company states that it will adopt an integrated pest management program to minimise the use of chemical pesticides and hazardous material. However, no information is provided about its implementation.

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

The company reports it has a solid waste management process in place to safely dispose of hazardous waste from its pulp and paper production operation. However, this is only self reported.

124. Commitment to human rights?

The company's states its commitment to the Universal Declaration of Human Rights.

125. Commitment to human rights applies to all suppliers?

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

126. Progress on human rights commitment ?

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

The company has a commitment to respect indigenous people and local communities rights.

128. Commitment to indigenous and local communities' rights applies to all suppliers?

The company has a commitment to respect indigenous people and local communities' rights that applies to all its suppliers.

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

The company has a commitment to respect legal and customary land tenure rights.

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

The company has a commitment to legal and customary land rights that applies to all suppliers.

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

The company has a commitment to free, prior, and informed consent (FPIC).

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

The company has a commitment to free, prior, and informed consent (FPIC) applies to all suppliers.

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

The company has provided the process of free, prior, and informed consent with limited details.

134. Examples of local stakeholder engagement to prevent conflicts?

The company holds meetings with local stakeholders (including NGOs, Academia, and government officials) and posts minutes online. As only one example of engagement to prevent conflicts is available partial points have been awarded.

135. Details of process for addressing land conflicts available?

The company reports it has a process for the resolution of land conflicts, but limited details are provided.

136. 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.

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

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

139. Commitment to provide essential community services and facilities ?

The company commits to provide essential community services and facilities in its Sustainable Forest Management Policy 2.0.

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

[Externally verified] 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.

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

The company has an explicit commitment to provide business/work opportunities for local communities.

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

The company has its own commitment and also makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's PEFC CoC certification.

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

The company has its own commitment and also makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's PEFC CoC certification.

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

[Externally verified] The company only reports having a Stakeholder Advisory Committee (SAC) which regularly reviews the progress on implementation of Sustainable Forest Management Policy (SFMP 2.0) which includes a commitment to worker's rights as well. However, there are no dedicated teams or committees for worker's rights commitment implementation. Points for external verification have been awarded on the basis of the company's PEFC and SVLK certifications.

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

The company has published this commitment.

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

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

149. Percentage or number of temporary employees?

20,111 - Number of contractrors as of December 2019: 20,111 (excluding suppliers' contractors).

150. Percentage or number of women employees?

3,709 (18.44%) - The company reports 3,709 women employees across all its operations.

151. Commitment to pay at least minimum wage?

The company has published a commitment to pay all workers minimum wage.

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

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

154. Reporting of salary by gender?

155. Commitment to address occupational health and safety?

The company commits to address health and safety but does not reference the ILO Code of Practice on Safety and Health in Forestry Work.

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

The company states its commitment to protecting the health and safety of workers which applies to all suppliers but the commitment does not refer to ILO Code of Practice.

157. Provision of personal protective equipment and related training?

The company has provided training and briefing to all employees, new hires, and contract workers on OHS principles and work procedures to protect them from exposure to occupational health and safety hazards.

158. Time lost due to work-based injuries?

Fatalities-5, Frequency rate-0.7, Injury rate-0.34, Lost day rate- 7.034 in 2019.

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

5 - The company reports that five fatalities occurred across APRIL's forestry operations in 2019.

160. Commitment to support smallholders?

The company has provided multiple examples to support smallholders. However, no such commitment found.

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

[Externally verified] The company provides support to farmers in improving skills in agricultural activities such as horticulture, plantation, animal husbandry, fishery, and paddy planting development and also provides training, facilitation, and technical support to farmers. It also has a community fiber plantation and livelihood plantation program to provide welfare and economic support to farmers. Evidence has been externally verified by KPMG in a written report.

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

15 - The company reports that in 2019 it supported 15 community fiber plantations that cover 8,241 ha and Livelihood plantations that cover an area of 27,064 ha.

163. 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.

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

[Externally verified] The company reports the percentages of new suppliers assessed on its due diligence process. It is not clear if all suppliers have been assessed by this process. The data is externally verified by KPMG in a written report, however it should be noted that during verification KPMG identified gaps in the data showing a supplier was able to do business with the company without fully completing the due diligence process.

165. Suspension or exclusion criteria for suppliers?

The company state that all those suppliers that do not comply with or are in violation of APRIL'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.

166. 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 the suppliers to be in compliance with sustainable timber and pulp sourcing commitments.

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

[Externally verified] The company states that all the direct and indirect supply comes from FMUs which are compliant with timber and pulp sourcing policies, and has provided a description of all its fiber supply which are compliant with timber and pulp sourcing policy. Some data is externally verified in a report written by KPMG, however, this only covers legality and not company sustainability sourcing commitments.

168. Commitment to ethical conduct and prohibition of corruption?

The company has an explicit commitment to ethical conduct and the prohibition of corruption.

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

Only the commitment to prohibition of bribery applies to all suppliers.

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

The company has provided training to its employees and also has a stakeholder advisory committee that oversees the implementation of sustainable forest management policy 2.0. In 2018, its Human Resources team conducted 117 Core Value training attended by a total of 6,893 APRIL employees.

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

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

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

This indicator is disabled as the company reports that it doesn't operate in a geography currently covered by Open Timber Portal.

174. Whistleblowing procedure?

The parent company (RGE Group) has a webpage where it indicates an email address to report cases and states that reporters' identity is protected with strict confidentiality. However, no details on the procedure (e.g.: steps taken when an issue is raised) are published.

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

The company has its own grievance system open to all stakeholders.

176. 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.