APRIL

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

The company has a 'Sustainable Forest Management Policy' for all its 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?

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

1 - Out of six senior managers, one is a woman.

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, UNGC, WBCSD, TFA, HCVN 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 company's forestry operations.

9. Sustainability report published within last two years?

The company published a Sustainability Report in 2022 reporting on 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.

12. Natural capital assessment available?

13. Lists countries and operations?

The company's activity (pulp & paper mills, plantations) is in Indonesia.

14. Lists countries sourcing from?

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

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)?

448,632 - The company has 448,632 ha area of plantation, including the area of its supply partners.

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

31,867 - The company reports it has a total 31,867 ha plantation area within its outgrower scheme as of December 2020.

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)?

364,996 - The company has a 364,996 ha conservation and restoration area.

20. 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.

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 geo-referenced maps of company FMUs are available 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 sustainability dashboard.

29. Number of company owned sawmills?

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

30. Names and locations of company owned sawmills?

This indicator is disabled as the company reports that it does not 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?

The name and location of the company's pulp and paper mill is available on the company website.

33. 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.

34. 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 sourced a total wood fibre supply of 11,098,933 tonnes in 2020. 4,126,772 tonnes came from its own plantations, 4,362,569 tonnes came from supply partners, 2,271,565 tonnes came from open market suppliers and 338,027 tonnes came from community fibre plantations.

35. Number of third party supplying mills?

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

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

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

The company makes this commitment through SVLK and PEFC CoC 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.

39. 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.

40. Procedures to trace raw materials to FMU level?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as PEFC requirements do not fully meet the SPOTT scoring criteria, and a procedure to trace raw materials to FMU level is not reported by the company.

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 89%).

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 supply 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 also 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 reports a commitment to source wood/wood fiber that meet PEFC Controlled Wood source requirements.

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

81% - The company states that 81% of its concession areas are PEFC FM certified.

51. Commitment to zero conversion of natural ecosystems?

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

53. Commitment to zero deforestation?

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

54. Commitment to zero deforestation applies to all suppliers?

The commitment applies to all suppliers.

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

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

56. 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. However, only some of this information has been externally verified in a report written by KPMG.

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

[Externally verified] The company states 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 timeframe. However, only some of this information is externally verified in a report written by KPMG.

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

11 - The company reports 11 ha of forest loss due to encroachment in 2020. The total figure since the cut-off date is not available.

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

112 - The company reports 112 ha of forest loss due to encroachment in its supplier conservation areas in 2020.

60. Commitment to restoration of deforestation/conversion?

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

61. Commitment to restoration of 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 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.

62. 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. In addition, the company states that it conducts land use on a "whole-of-landscape" basis, but limited details are available regarding how this is implemented.

63. Biodiversity policy?

The company commits to preserve and restore biodiversity, has published positive biodiversity gains targets and reports on progress.

64. Biodiversity policy applies to all suppliers?

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

[Externally verified] The company has identified species of concern using the IUCN Red List; this has been externally verified in an assurance statement from KPMG.

66. 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.

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

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

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

69. Commitment to protect forest areas from illegal activities?

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

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

71. 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 reports that its team conducts daily patrols and logs any illegal activity or activity that does not comply with the company's policies.

72. Commitment to no use of genetically modified organisms?

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

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

The commitment apply to all suppliers.

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

The company reports its commitment to conduct High Conservation Value (HCV) assessments.

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

The company commits its suppliers to conduct High Conservation Value (HCV) assessments.

76. High Conservation Value (HCV) assessments available?

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

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

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

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

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

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

The commitment applies to all suppliers.

80. High Carbon Stock (HCS) assessments available?

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

81. 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.

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

The company only commits to conduct EIA or AMDAL (environmental assessments) and social impact assessments.

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

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

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

85. 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.

86. 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.

87. 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.

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

244,271 - The company reports 244,271 ha of peatland in its landbank in 2021.

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

The company reports a reduction in its planted area on peat from 244,551 in 2020 to 244,271 in 2021.

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

The company reports its commitment to best management practices for soils and peat.

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

The company only commits its suppliers to best management practices for peat. A commitment to best management practices for soil is not reported by the company.

92. 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's own reporting also covers best management for peat and soil which includes commissioning of an Independent Peat Expert Working Group and the mechanisation of harvesting to minimise the environmental impact as the cut-to-length system helps to keep organic matter spread across field areas, which improves soil nutrition and limits soil erosion.

93. Commitment to reduced impact logging?

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

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

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

95. Evidence of implementing reduced impact logging practices?

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

96. Commitment to zero burning?

The company reports it has a strict "No Burn" policy and follows the national legal requirement addressing impact of fires.

97. Commitment to zero burning applies to all suppliers?

The company commits all its suppliers to its strict "No Burn" policy.

98. 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 percentage of company landbank certified by PEFC. The company also reports that it uses satellite hotspot monitoring technologies, and that it has spotting capabilities through fire monitoring towers and closed-circuit television cameras; this has been externally verified by KPMG.

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

5 - The company reports five fire incidents inside its concession area in 2020.

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

2 - The company reports two fire incidents on supply partners' concession areas in 2020.

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

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

102. GHG emissions intensity?

The company reports scope 1 emissions as 0.5 MTCO2e/t in 2021. Figures only cover mills and not operations further upstream.

103. GHG emissions from land use change?

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

104. 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. Information is not externally verified.

105. Methodology used to calculate GHG emissions?

The company's GHG inventory follows the GHG Protocols Corporate Standards and GHG Protocol Agricultural Guidance authored by the World Business Council for Sustainable Development (WBCSD) and the World Resources Institute (WRI).

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

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

107. 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.

108. 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, 79.1 in 2020). However, the figures reported are not intensity based, and water use is not improving.

109. 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.

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

The company reports progress towards its commitment on 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 not externally verified.

111. Treatment of pulp and paper mill effluent?

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

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

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

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

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

114. Commitment to protect natural waterways through buffer zones?

The company commits to protect natural waterways using buffer zones.

115. 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 provides limited details on the use of plantation buffer zones referring to conservation areas.

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

The company has a "Pesticide and Other Hazardous Materials Use" policy which includes a company's commitment to minimise the use of chemicals, including pesticides and chemical fertilisers.

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

The company's "Pesticide and Other Hazardous Materials Use" policy applies to all suppliers.

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

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

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

The company reports a commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides.

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

The company's commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers.

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

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

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

The company's commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers.

123. 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.

124. Implementation of commitment to reduce chemical usage?

The company states that insecticide application on plantations reduced by 27% between 2020 and 2021 and a reduction of 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.

125. Integrated Pest Management (IPM) approach?

Additional points have been awarded according to the percentage of company landbank certified by PEFC. The company reports that it implements an integrated pest management program to minimise the use of chemical pesticides. This information is externally verified by KPMG.

126. 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 reports on multiple dimensions of its waste management system.

127. Commitment to human rights?

The company reports its commitment to respect the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

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

129. 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. Information is not externally verified.

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

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

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

The company makes this commitment through SVLK certification requirements. As SVLK requirements do not fully meet the SPOTT indicator criteria, partial points have been awarded for this indicator on the basis that 100% of the company's wood/woodfibre supply is SVLK certified. 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.

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

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

133. 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.

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

The company reports its commitment to free, prior and informed consent (FPIC).

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

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

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

The company only reports limited details on FPIC.

137. 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, and it conducts participatory mapping and other engagement activities with communities to develop conservation plans. Partial points have been awarded as the information is self-reported.

138. Details of process for addressing land conflicts available?

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

139. 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 not externally verified.

140. 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.

141. 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.

142. Commitment to provide essential community services and facilities ?

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

143. 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.

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

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

145. 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.

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

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

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

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

148. 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 percentage 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.

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

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

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

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

152. Percentage or number of temporary employees?

22,174 - Number of contractors as of December 2020: 22,174 (excluding suppliers' contractors).

153. Percentage or number of women employees?

6,179 (20%) - The company reports 6,179 women employees across all its operations.

154. Commitment to pay a living wage?

The company only reports commitment to pay minimum wage.

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

156. Progress on commitment to pay a living wage?

157. Reporting of salary by gender?

158. Commitment to address occupational health and safety?

The company reports a commitment to address health and safety at work, referencing the ILO Code of Practice on Safety and Health in Forestry Work.

159. 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 as the requirements do not fully meet the SPOTT scoring criteria. The company's own commitment for suppliers does not refer to the ILO Code of Practice on Safety and Health in Forestry Work.

160. 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 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.

161. Time lost due to work-based injuries?

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

3 - The company reports that three fatalities occurred across its forestry operations in 2020.

163. Commitment to support smallholders?

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

The company reports it has a livelihood plantation program to provide welfare and economic support to smallholders. in 2020 31,837 hectares had been allocated to the programme. However, this information is not externally verified.

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

The company reports that in 2020, a total of 31,867 hectares had been allocated as livelihood plantations, with 152 villages participating in the scheme. However, the information reported is not externally verified.

166. 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.

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

[Externally verified] It is reported that the company had no new suppliers in 2019 and 2020. As for existing suppliers, they are subjected to an annual due diligence process, but not all field visits could be conducted due to the covid-19 pandemic. As the company does not publish figures on the number or percentage of suppliers for which the due diligence process was completed, or on the number of field visits it could conduct, only partial points are given. This information is externally verified and published in a KPMG report.

168. Suspension or exclusion criteria for suppliers?

The company reports that all suppliers that do not comply with or are in violation of 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.

169. 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.

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

The company reports that all of its fiber 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, this does not covers indirect supply, and none of this information is externally verified.

171. Commitment to ethical conduct and prohibition of corruption?

The company reports commitment to ethical conduct and the prohibition of corruption.

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

The company only commits its suppliers to prohibition of bribery. A commitment to ethical/fair conduct is not reported for suppliers.

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

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. However, the information is not externally verified.

174. 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.

175. Disclosure of the company’s management approach to tax and payments to governments?

176. 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.

177. 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.

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

The company has a grievance procedure which is open to all stakeholders.

179. 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.