APRIL

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

Sustainable Forest Management Policy 2.0.

2. Sustainability policy or commitment applies to all sourcing?

3. High-level position of responsibility for sustainability?

Sustainability Director.

4. One or more board members have responsibility for sustainability?

This indicator is disabled as the company is not publicly listed.

5. Percentage or number of women board members?

This indicator is disabled as the company is not publicly listed.

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

The company only provides figure on total number of management in 2017 (19) but it is unclear how many are women. An undated leadership webpage only shows seven leaders one of which is a woman.

7. Sustainability report published within last two years?

2017

8. Member of multiple industry schemes or other external initiatives to improve forest management or transparency?

Fire Free Alliance, TFA 2020, WBCSD, UNGC, PEFC.

9. Activities with government, NGOs or academic institutions to improve the sustainability of forest products?

Stakeholder Advisory Committee, Rainforest Alliance, Independent Peat Expert Working Group.

10. Climate risks assessment available?

11. Natural capital assessment available?

12. Lists countries and operations?

Indonesia (plantation, pulp and paper mill).

13. 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 plantation forests.

14. Total area of forest plantation (ha)?

455015 - 209,252 ha controlled by the APRIL subsidiary PT Riau Andalan Pulp & Paper. A further 237,415 ha is controlled by supply partners and 8,348 ha by community forestry.

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

22703 - The company and its supply partners implement outgrower programs such as livelihood plantation or Tanaman Kehidupan (14,355 ha) and community forestry (8,348 ha).

16. 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.

17. Conservation set-aside and/or HCV area (ha)?

369420 - PT. RAPP (69,972 ha), supply partners (148,596 ha), ecosystem restoration licenses (150,852 ha). These figures exclude conservation areas that are under land claims: approximately 18,000 ha for PT RAPP and 22,000 ha for supply partners.

18. Area of Intact Forest Landscape (ha)?

This indicator is disabled as the company has informed ZSL that it doesn't have any intact forest landscapes within its landbank.

19. Number of Forest Management Units (FMUs)?

12 - PT RAPP Teluk Meranti consists of two entities: PT RAPP Meranti East and PT RAPP Meranti West.

20. Maps of forest management units (FMUs)?

PT RAPP Teluk Meranti consists of two entities: PT RAPP Meranti East and PT RAPP Meranti West.

21. Forest management plans available for all FMUs?

22. Monitoring of forest management plan implementation?

23. Company has provided valid legal documents to Open Timber Portal on use 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.

24. 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.

25. 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.

26. Number of company owned pulp and paper mills?

1 - Kerinci mill, Riau Province, central Sumatra.

27. Maps or addresses of company owned pulp and paper mills?

28. Number of company owned sawmills?

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

29. Maps or addresses of company owned sawmills?

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

30. Number of supplier mills?

The company has a list of its suppliers that is only accessible after login therefore it is not considered publicly available.

31. Maps or addresses of supplier mills?

The company has a list of its suppliers that is only accessible after login therefore it is not considered publicly available.

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

The company reports that all of its supply is PEFC, SVLK and FSC certified. These certifications count as procedures to trace raw materials. Since all of the company's supply is certified full points have been awarded (as of December 2017).

33. Procedures to trace raw materials to FMU level?

The company reports that all of its supply is PEFC, SVLK and FSC certified. These certifications count as procedures to trace raw materials. Since all of the company's supply is certified full points have been awarded (as of December 2017).

34. Percentage of supply traceable to country level (above 80%)?

100% - The company reports that all of its supply is PEFC, SVLK and FSC certified. These certifications count as procedures to trace raw materials. Since all of the company's supply is certified full points have been awarded (as of December 2017).

35. Percentage of supply traceable to FMU level (above 75%)?

100% - The company reports that all of its supply is PEFC, SVLK and FSC certified. These certifications count as procedures to trace raw materials. Since all of the company's supply is certified full points have been awarded (as of December 2017).

36. Commitment to zero conversion of natural forest?

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.

37. Zero conversion commitment applies to all sourcing?

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.

38. Commitment to minimise the impact of logging roads?

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

39. Commitment to protect forest areas from illegal activities?

Fire teams patrol company concession areas, monitoring the landscape for fires as well as other unauthorised activities, including illegal logging.

40. Evidence of monitoring deforestation?

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.

41. Amount of deforestation recorded?

762.4

42. Commitment to biodiversity conservation?

43. 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.

44. Implementing a landscape-level approach to biodiversity conservation?

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

46. Commitment to sustainably manage the use of non-timber forest products (NTFPs)?

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

47. Commitment not to use genetically modified organisms?

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

The company will only develop areas that are not forested, as identified through independent peer-reviewed HCV and HCS assessments.

49. HCV commitment applies to all sourcing?

The company commits to only develop areas that are not forested, as identified through independent peer-reviewed HCV and HCS assessments. This commitment is said to apply to all current and future wood suppliers as well as any future acquisitions or partnerships.

50. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?

The company states that it will use licenced assessors from the HCV Resource Network (HCVRN). When such assessors are not available, the company will seek an assessor recommended by its Stakeholder Advisory Committee. This commitment also applies to the company's suppliers.

51. High Conservation Value (HCV) assessments available?

One HCV-HCS assessment is available for Marga Madani and Padu Pilihan cooperatives, West Sumatra. However this does not cover all of the company's operations.

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

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

The company and its suppliers will only develop areas that are not forested, as identified through independent peer-reviewed HCV and HCS assessments. The company will follow the HCS Approach as prescribed by the HCS Approach Steering Group.

54. High Carbon Stock (HCS) assessments available?

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

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

The company states that forest plantation areas have undergone Environmental Impact Assessments and Social Impact Assessments are currently being undertaken.

56. Social and environmental impact assessments (SEIAs) available?

57. 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.

58. Commitment to best management practices for soils and/or peat?

The company has a commitment to best management practices for peat. No equivalent commitment could be identified for other soil types.

59. Commitment to reduced impact logging?

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

60. 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.

61. Commitment on peatland planting applies to all sourcing?

The company has a commitment not to develop 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.

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

256682 - Figure calculated by adding PT RAPP's (111,206 ha), community fibre plantations' (6,653 ha) and long-term suppliers' (138,823 ha) landbank on peat.

63. Evidence of best management practices for soils and/or peat?

The company provides evidence of best management practices for peat (management of water levels) and has commissioned an Independent Peat Expert Working Group. No best management practices could be identified for other soils.

64. Commitment to zero burning?

65. Commitment to zero burning applies to all sourcing?

66. Evidence of management and monitoring fires?

Community and education-based prevention initiatives; regular land, air and water patrols. Suppression capabilities include helicopters equipped with fire crews, water bombing, fire trucks, and airboats.

67. Details/number of hotspots/fires in FMUs controlled by the company?

51 - As a result of the company's fire suppression program the total hectares lost to fire on PT RAPP and its long term supplier concessions during the reporting period was limited to 51 hectares.

68. Time-bound commitment to reduce GHG emissions intensity?

The company states that it commits to continuous reduction of its carbon footprint. However, no specific target on GHG intensity could be identified.

69. Progress towards reducing GHG emission intensity?

Mill tonnes of GHG/tonne of paper: 0.44 metric ton CO2eq/ton pulp (2017); 0.72 metric ton CO2eq/ton paper (2017). The company has not set a target for reducing GHG intensity.

70. Report GHG emissions from land use change?

The company states that research is underway to establish land use emissions and sequestration associated with plantation operations.

71. 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.

72. 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.

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

COD Treated Waste Water: 6.8 m3/adt (2013), 8.3 (2014), 7.5 (2015), 5.45 (2016), 5.54 (2017); BOD Treated Waste Water: 0.61 measured kg/adt (2013), 0.55 (2014), 0.60 (2015), 0.70 (2016), 0.64 (2017).

74. Commitment to protection of natural waterways through buffer zones?

Commitment covers the provision of buffer zones in conservation areas only.

75. Evidence of treatment of pulp and paper mill effluent?

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

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

77. 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 and is not time-bound.

78. Progress towards commitment on water use intensity?

24 - Water Consumption for Pulp and Paper: 32.7 m3/adt (2013), 29.6 (2014), 29.5 (2015), 27.3 (2016), 24 (2017). Partial points as no specific target has been set.

79. Commitment to eliminate chlorine and chlorine compounds for bleaching?

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

81. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

82. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

83. Integrated Pest Management (IPM) approach?

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

85. Commitment to human rights, referencing the UN Declaration on Human Rights or UN Guiding Principles on Business and Human Rights?

86. Commitment to human rights applies to all sourcing?

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

88. Commitment to respect legal and customary property rights?

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

90. FPIC commitment applies to independent suppliers?

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

The company provides a case study of how FPIC is implemented.

92. Examples of local stakeholder engagement to prevent conflicts?

The company undertakes community engagement activities in relation to land conflicts, encroachments and fire prevention.

93. 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.

94. Commitment to support the inclusion of women across forestry operations, including addressing barriers faced?

The company provides examples on how it supports the inclusion of women in forestry operations but no commitment found.

95. Commitment to provide essential community services and facilities?

96. 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.

97. Commitment to respect all workers' rights?

98. Reference to Fundamental ILO Conventions?

The company states that the ILO's Declaration on Fundamental Principles and Rights at Work is respected.

99. Commitment to eliminate gender related discrimination with regards to employment and occupation?

100. 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.

101. Percentage or number of temporary employees?

9182 (74.8%) - Contractors as of December 2017 excluding the company's supply partners.

102. Percentage or number of women employees?

650 (9.25%) - Direct employees as of December 2017 excluding the company's supply partners.

103. Payment of minimum wage?

The company states that it complies with Indonesian labour law, which covers the minimum wage. No evidence of wages paid is provided.

104. Reporting of salary by gender?

105. Commitment to address occupational health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work?

The company does not reference the ILO Code of Practice on Safety and Health in Forestry Work.

106. Time lost due to work-based injuries?

Injury Rate (employees & contractors): Fibre operations male: 0.44 female: 0.04; Mill male: 1.27, female: 0 (2017).

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

1 - The company reports that one contractor in its forestry operations lost their life during 2017.

108. Provision of personal protective equipment and related training?

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

100% - The company has already achieved 100% third-party legality verification.

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

100% - All the company's suppliers are already third-party verified (SVLK, PEFC, FSC).

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

100% - Sustainable Production Forest Management and Timber Legality Verification (PHPL-SVLK), PEFC.

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

100% - SVLK, PEFC (as of 2017).

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

114. Commitment to source only wood/wood fibre that meets FSC Controlled Wood requirements?

115. Percentage area (ha) FSC FM certified?

116. Percentage of wood/wood fibre supply from outgrower scheme and/or independent suppliers that is FSC FM certified?

117. Percentage of all wood/wood fibre supply traded/processed that are FSC certified (above 75%)?

3.1% - Only 3.1% of all the company's supply is FSC (CoC) certified.

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

262473 (77.5%) - 262,473 ha out of a total of 338,536 ha of the company's own area is certified.

119. Programme to support outgrower scheme smallholders?

Livelihood farms, Community Fibre Farms. Providing training, seedlings, fertiliser, financing, technical support.

120. Percentage of outgrower scheme smallholders involved in programme?

15 - The company supports 15 community fibre plantations (Hutan Rakyat) that cover 14,355 ha, 3% of the company and its partners' plantation area.

121. 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 suppliers.

122. The company has a Due Diligence System (DDS)?

123. Suspension or exclusion criteria for suppliers?

124. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

100%

125. Commitment to ethical conduct and prohibition of corruption?

Guidelines include provisions for fair and non-discriminatory engagement with stakeholders, avoidance of conflicts of interest and intolerance of corrupt practices.

126. 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.

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

128. 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.

129. Whistleblowing procedure?

The company's parent, Royal Golden Eagle, has a whistleblowing policy and provides an email address to report cases. This is applicable to the company as well, however no details on steps taken or how whistleblowers are protected are provided.

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

131. Details of grievances disclosed?