Bracell

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

The company has a sustainability policy that covers all its forestry operations, along with its Sustainability Report 2020 which specifies sustainability and ethical commitments.

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

The company's sustainability policy does not apply to suppliers. The company has Codes of Conducts for suppliers but they are limited in scope and do not cover a range of environmental or social issues.

3. High-level position of responsibility for sustainability?

Executive Vice President is in charge of a Steering Committee that has responsibility for sustainability.

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

The company states the Steering Committee was set up by general directors, but it isn't clear if a director sits on the committee or is responsible for sustainability at the board level.

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

1 - In 2020, the company's operations in Bahia the are 0/5 and in São Paulo there 1/17 women in the senior management team.

6. Percentage or number of women board members?

0 - In 2020, the company's operations in Bahia the are 0/3 and in São Paulo there 0/2 women on the board of directors.

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] UNGC, FSC, Cerflor/PEFC, CEBDS, IPEF.

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

The company works with local communities that have been impacted by illegal deforestation and polluted water sources to restore watersheds.

9. Sustainability report published within last two years?

The company published the latest Sustainability Report in 2020.

10. Reports through standardised reporting systems?

The company has prepared its Sustainability Report 2020 in accordance with Global Reporting Initiative (GRI) Standards.

11. Climate risks assessment available?

The company has conducted a study on climate impacts to eucalyptus cultivation, however, no assessment/data has been published. The information is not externally verified. Hence awarded only partial points.

12. Natural capital assessment available?

13. Lists countries and operations?

Brazil (Bahia and Sao Paulo).

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)?

95,429 - The total area planted with trees for wood/wood fibre production in Bahia is 95429 ha, excluding smallholder/outgrower scheme areas. Planted area for São Paulo is not reported.

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

23,552 - Outgrower schemes cover an area of 23,552 ha. However, this only covers the company's operations in Bahia.

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

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

The company states on its webpage that it preserves 89,561 ha of natural areas, however, this information is undated, and the latest dated figure (83,000 in 2020) does not match the figure on the webpage. Partial points have been awarded for contradictory information.

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)?

154 - The company's PEFC certification specifies 154 FMUs in Bahia. However, the figure clearly does not represent all of the company's FMUs.

22. Maps of forest management units (FMUs)?

The company's PEFC (Cerflor) certification lists 154 FMUs with geo-referenced coordinates for Bahia only but for Sao Paulo region, only a static map is available representing the company's own, partnership and promoted landbanks in forest management plan summary.

23. Forest management plans available for all FMUs?

A forest management plan is available publicly for both regions of operations (Sao Paulo and Bahia).

24. Monitoring of forest management plan implementation available?

The company has reported that monitoring information can be found in the audit report, however, it covers only one FMU in the Sao Paulo region.

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 provided a static map representing the company's own, partnership and promoted landbanks. Maps are not geo-referenced.

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?

2 - The company has two mills, one mill is located in Sao Paulo and one in Bahia.

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

The company has published addresses for both of its mills.

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?

35. Number of third party supplying mills?

This indicator is disabled as the company reports that it does not source from supplying mills.

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

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

This indicator is disabled as the company reports that it does not source from supplying mills.

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

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified.

39. Percentage of supply traceable to country of harvest?

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC 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 the requirements do not fully meet the SPOTT scoring criteria.

41. Percentage of supply traceable to FMU level?

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

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

The company reports that 91% Bahia and 83% São Paulo operations are PEFC FM certified, however an overall percentage of operations covered by PEFC FM cannot be calculated as the company has not disclosed a landbank for São Paulo. A PEFC FM certificate is available for Bahia only, no certificate confirming the area certified in São Paulo can be found.

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

All supply in 2020 was PEFC CoC certified.

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

100% - The company has reported that 100% of the wood used in the pulp production process comes from certified forests or non-controversial sources by PEFC.

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's sustainability report states that the wood used in the pulp production process is entirely sourced from PEFC-certified forests or controlled sources.

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

The company reports that 91% Bahia and 83% São Paulo operations are PEFC FM certified, however an overall percentage of operations covered by PEFC FM cannot be calculated as the company has not disclosed a landbank for São Paulo. A PEFC FM certificate is available for Bahia only, no certificate confirming the area certified in São Paulo can be found.

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 has published this commitment. The company also makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

54. Commitment to zero deforestation applies to all suppliers?

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified.

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

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Partial points have been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified and the certification requirements do not fully meet the SPOTT indicator criteria.

56. Evidence of monitoring deforestation and/or ecosystem conversion?

The company reports there are 24 hour patrols by security teams to stop encroachment in its operations in Bahia. The company also reports the use of drones with thermal cameras. Information is not externally verified.

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

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

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

60. Commitment to restoration of deforestation/conversion?

61. Commitment to restoration of deforestation/conversion applies to all suppliers?

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.

63. Biodiversity policy?

The company commits to protect natural resources in its own operations and maintaining biodiversity.

64. Biodiversity policy applies to all suppliers?

The company commits to protect natural resources in its own and in partners/suppliers' operations and to maintain biodiversity.

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

The company has identified species of conservation concern referencing the IUCN Red list and ICMBio.

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.

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

The company commits towards no hunting to protect its plantation.

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 has a commitment to protect forest areas from 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.

72. Commitment to no use of genetically modified organisms?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

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

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership. The company also reports this commitment.

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

76. High Conservation Value (HCV) assessments available?

The company published a summary of HCV assessment in a forest management plan, however, this only covers the Sao Paulo area.

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

The company's forest management plans include summaries of how HCV are managed and monitored. Partial points have been awarded as plans are not externally verified.

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

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

80. High Carbon Stock (HCS) assessments available?

81. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

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

The company makes this commitment in its sustainability policy under the section of impact identification and monitoring.

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?

The company includes some elements of social and environmental impact assessment in its forest management plans for both regions however, these don't include management and monitoring plans.

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 stated a commitment that it does not operate on peat soils.

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

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

0 (0%) - The company states that it has no landbank on peat.

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

This indicator is disabled as the company reports that it does not have landbank on peat.

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

The company provides information on best management practices for soils and states that it does not have landbank on peat.

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

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

The company reports that it does not have operations on peatland. 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.

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 has a commitment to zero burning.

97. Commitment to zero burning applies to all suppliers?

The company's commitment to zero burning applies to all suppliers.

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.

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

49 - In 2021, the company recorded 49 firefighting fires in its areas.

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

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

The company only has a vague commitment to reduce GHGs, but it is not time-bound, nor expressed in intensity.

102. GHG emissions intensity?

The company reports total GHG emissions as equal to 237.809 tons of carbon equivalent in 2020. However, this is not expressed in intensity. A figure for Bahia operations is reported in intensity (0.770 Kg CO e/kg of soluble cellulose) but a figure could not be found for São Paulo operations.

103. GHG emissions from land use change?

104. Progress towards commitment to reduce GHG emissions intensity?

[Externally verified] The company reports a 10% reduction in emissions between 2018 and 2019 in the region of Bahia, but the figure is not expressed in intensity. This data has been externally verified by SGS via an assurance statement. However, information found is between two to five years old.

105. Methodology used to calculate GHG emissions?

GHG Protocol methodology.

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

The company has reported that in 2020, water use in the industrial area of Bahia decreased by 1.2% compared to the previous year. However, in São Paulo, the target proposed for the year, of maintaining an average of less than 23 m³ per ton produced, was not achieved in 2020.

107. Water use intensity?

31.78 - For 2020, the company reports water use intensity for Bahia as 31.78 m³ per ton. Figures of water use at Sao Paulo are published but not given in intensity (591,593 m3of).

108. Progress towards commitment on water use intensity?

[Externally verified] The company reports a decrease in water use for Bahia operations, in the year 2020, 901,951 m3, 8.8% less than in 2019. However, in Sao Paulo operations the company only reports its water use figures. Data has been verified with an assurance statement in the company's sustainability report.

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

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

The company reported a reduction in the organic effluent generated from 25.8 m³/admt in 2017 to 25.4 m³/admt in 2018 and from 19.7 m³/admt in 2017 to 19.8 m³/admt in 2018 in Bahia and São Paulo respectively. However, the information is between two to five years old. Hence awarded only partial points.

111. Treatment of pulp and paper mill effluent?

[Externally verified] The company has effluent treatment stations for treating the pulp and paper mill effluent. This information has been externally verified by SGS via a written assurance statement.

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?

[Externally verified] Water reuse and closed circuit practices are used at both processing locations. This information has been externally verified by SGS via a written assurance statement.

114. Commitment to protect natural waterways through buffer zones?

The company includes a commitment towards riparian zones or protecting waterways in forest management plans for both FMU units.

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

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.

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

The company has a 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?

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

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

Forest management plan for both the units states the commitment towards no use of Class 1A and 1B pesticides.

120. 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?

122. 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?

Chemical usage for Bahia operations is included in a PEFC audit. However, this does not cover the full scope of operations, also the information is between two to five years old.

124. Implementation of commitment to reduce chemical usage?

125. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's PEFC FM certification (PEFC ST 1003:2018) as the requirements fully meet the SPOTT indicator criteria.

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

[Externally verified] The company provides detail of a waste management system. Evidence is verified by SGS via an assurance statement.

127. Commitment to human rights?

The company is committed to respecting and supporting the Universal Declaration of Human rights. The company also makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0).

128. Commitment to human rights applies to all suppliers?

129. Progress on human rights commitment ?

[Externally verified] The company provides human rights training to its employees and has an internal audit team. The evidence is verified by third-party assurance.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification/membership.

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

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's subsidiary's FSC membership.

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

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Full points have therefore been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified.

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

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

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

137. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company uses devices such as social mapping and meetings with communities to prevent stakeholder conflict. The evidence is verified by third party assurance.

138. Details of process for addressing land conflicts available?

The company reports that it tries to resolve conflicts with the affected parties before any judicial alternatives, however, details on the process are limited.

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

[Externally verified] The company has reported many examples of its initiatives to support the inclusion of women across forestry operations. The evidence is verified by third party assurance.

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 is committed to providing essential services to the community based on education, empowerment, and well being.

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

The company has reported several examples of providing essential community services and facilities. The evidence is verified by third party assurance.

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

The company makes the commitment to provide business/work opportunities for local communities in its sustainability report.

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 has published this commitment. The company also makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0).

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

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Partial points have been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified and the certification requirements do not fully meet the SPOTT indicator criteria.

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.

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

The company clearly states a commitment to eliminate gender-related discrimination in its sustainability policy.

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

The company clearly states a commitment to eliminate gender-related discrimination in its sustainability report that applies to all suppliers.

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

The company has signed the UN Women's Empowerment Principles (WEPs) but it has not disclose the actions it has taken to eliminate gender discrimination in the workplace.

152. Percentage or number of temporary employees?

88 - In 2020, the company employed 88 contract workers.

153. Percentage or number of women employees?

813 - The company reports 23% of women in the Sao Paulo region and 20.8% of women in the Bahia region respectively.

154. Commitment to pay a living wage?

The company only commits to paying above the minimum wage. Hence awarded partial points.

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

156. Progress on commitment to pay a living wage?

[Externally verified] The company reports figures showing that it pays more than the minimum wage to its employees. The evidence is verified by third party assurance.

157. Reporting of salary by gender?

The company reports entry level wages per gender against the minimum wage. Full points cannot be scored as the ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation in line with GRI reporting, has not been reported.

158. Commitment to address occupational health and safety?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

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

The company makes this commitment through the PEFC International Standard (PEFC ST 2002:2020). Partial points have been awarded for this indicator as 100% of the company's wood/wood fibre supply is PEFC certified and the certification requirements do not fully meet the SPOTT indicator criteria.

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.

161. Time lost due to work-based injuries?

The company has reported accident rates for the forestry and industrial operations in both Bahia and São Paulo regions.

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

59 - The company has reported fatalities as a result of work-based accidents for both regions Bahia and São Paulo.

163. Commitment to support smallholders?

The company has a forest producer program as a part of its community development initiative to help local people develop forestry businesses.

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

[Externally verified] The company has a forest producer program for its community development initiative to help local people develop forestry businesses. The evidence is verified by third-party assurance.

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

194 - The company has 44 and 150 farmers engaged in its smallholder programs in Sao Paulo and Bahia, respectively.

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

The company has provided limited detail on the process used to prioritise, assess or engage suppliers in compliance with the company's policy. Hence, only partial points are awarded.

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

The company states 80.8% of suppliers in Sao Paulo and 76% in Bahia are registered. Registered suppliers are periodically assessed on health and safety, environment and labour obligations.

168. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2020). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

169. Timebound action plans (including Key Performance Indicators) for suppliers to be in compliance with timber and pulp sourcing commitments?

The company makes this commitment through the PEFC International Standard (PEFC ST 1003:2010). Full points have therefore been awarded for this indicator as 100% of the company's wood/woodfibre supply is PEFC certified.

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

171. Commitment to ethical conduct and prohibition of corruption?

The company has a Code of Conduct covering both ethical conduct and prohibition of corruption.

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

The company commits all suppliers to ethical conduct and prohibition of corruption.

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

[Externally verified] The company provides training to its employees on anti-corruption procedures, has set up an internal audit team to address the matters concerning the violation of its code of conduct including cases of corruption. The evidence is verified by third party assurance.

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 has a complaints policy which states maintaining anonymity and providing protection to whistleblowers.

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

The company has communication channels in place which are available for all the stakeholders.

179. Details of complaints and grievances disclosed?

The company has only disclosed the types of grievances.