Bracell

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

The company provides sustainability policy which covers all of its forestry operations, along with the sustainability report also discuss on the sustainability and ethical commitments.

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

The company's 2020 sustainability policy states that "it requires service providers to comply with all local laws and regulations". However, suppliers are not specified explicitly, and it is not clear whether they should comply to the company's policies and commitments.

3. High-level position of responsibility for sustainability?

The company has a Head of Corporate Relations and Sustainability, and teams in charge of Sustainability and Social Responsibility.

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

This indicator is disabled as the company reports that it is privately owned and/or does not have a Board of Directors.

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

1 - Company's operations in Bahia have no women in the senior management team, whereas in São Paulo there is one women out of 8 (12.50%) in the senior management team.

6. Percentage or number of women board members?

This indicator is disabled as the company reports that it is privately owned and/or does not have a 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] The company is a member of UNGC, FSC, Cerflor/PEFC, and IBA.

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

The company collaborates with academic institutions engaged in biodiversity monitoring, education on environmental protection. With São Paulo State Government the company is working for job creation of technical and professional qualified beneficiaries, in partnership with landowners of operational farmers the company assumes all costs of operating and maintaining forests.

9. Sustainability report published within last two years?

The company has published the latest sustainability report in the year 2019. The report covers both environmental and social details.

10. Reports through standardised reporting systems?

The report is prepared following GRI standards and published on the GRI database.

11. Climate risks assessment available?

The company has conducted a study on climate impacts to eucalyptus cultivation, however no full risk assessment including mitigation measures has been published.

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)?

100,829 - The total area planted with trees for wood/wood fiber production in Bahia is 100,829 ha, excluding smallholder/outgrower scheme areas. Planted area for São Paulo is not reported.

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

12,746 - Outgrower schemes cover an area of 39,854 ha, including 12,746 eucalyptus plantations. 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)?

89,561 - The company states on its website that it preserves 89,561 ha of natural areas, however this is undated, and the latest dated figure ("more than 83,000" in 2020) does not match the figure on the website. 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)?

380 - The company's FSC and PEFC certification documents list 154 FMUs in Bahia and 226 FMUs in Sao Paulo. However, FSC audit data is between two and five years old and the company's certification has since been terminated.

22. Maps of forest management units (FMUs)?

The company's PEFC (Cerflor) certification lists 154 FMUs with geo-referenced coordinates for Bahia 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 the both regions of operations (Sao Paulo and Bahia).

24. Monitoring of forest management plan implementation available?

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. Some externally-verified monitoring information can also be found in an audit report, however it only covers 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 doesn't own sawmills.

30. Names and locations of company owned sawmills?

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

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

2 - The company has total 2 mills, 1 mill is located in Sao Paulo and 1 in Bahia.

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

The company only publishes the cities in which its mills are located: Lençóis Paulista in Sao Paulo, Camaçari and Alagoinhas in Bahia.

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

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

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

The company reports that in the year 2019 its total pulp production reached 750,000 tons. The total volume sourced from the third-party suppliers is unclear.

35. Number of third party supplying mills?

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

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

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

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

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

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

The company has PEFC certificates but it isn't clear if it covers all of the company's supply. As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's PEFC CoC certification.

39. Percentage of supply traceable to country of harvest?

The company states that 100% of the wood used in pulp production comes from PEFC certified source.

40. Procedures to trace raw materials to FMU level?

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's PEFC CoC certification.

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?

63.6% - 63.6% of the company's operations (at least) are PEFC certified.

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

Some of the wood/wood fibre sourced by the company comes from PEFC certified forests, ensuring legal compliance verified by a third party. However, it is unclear what percentage this represents, and the company doesn't have any further commitment.

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

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?

The company sources only PEFC certified wood as stated in 2019 sustainability report.

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)?

63.6% - The company reports 137,070.57 is PEFC certified out of a total of 215,561 ha.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company s FSC certification/FSC membership. Also, has a commitment to no deforestation and a zero-burn policy.

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

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

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

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

54. Evidence of monitoring deforestation?

The company's sustainability report indicates the use of technologies such as patrols controlled by an intelligent GPS, and drones with thermal cameras. However the extent of the area monitored and timeframe are not specified.

55. Evidence of monitoring deforestation in supplier operations?

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

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

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

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

60. Implementing a landscape or jurisdictional level approach?

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

61. Commitment to biodiversity conservation?

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

62. Commitment to biodiversity conservation applies to all suppliers?

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

63. 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.

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

The company has provided multiple examples of species and habitat conservation such as preserving native vegetation using the Mosaic Landscape Approach, has a wildlife sighting program to maintain the species database, and identify potential threats from illegal encroachers and poachers in the environmental conservation areas. Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume.

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

The company commits towards no hunting to protect its plantation.

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

The company commitment to no hunting doesnot applies to suppliers.

67. Commitment to protect forest areas from illegal activities?

The company makes this commitment in its sustainability policy under the section ""environmental protection and conservation"".

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

69. Evidence of protecting forest areas from illegal activities?

Points for external verification have been awarded on the basis of the company's PEFC certified landbank/volume.

70. Commitment to no use of genetically modified organisms?

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

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

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

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

The company is committed to conducting HCV assessments. Also, makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership.

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

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

74. 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.

75. 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.

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

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

78. High Carbon Stock (HCS) assessments available?

79. 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.

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

The commitment to conduct social and environmental impact assessments (SEIAs) does not apply to suppliers.

81. 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.

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

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

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

The company states that it does not operate on peat soils, and commits to not do, using a recognized definition of peat.

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

The company does not report any commitment towards no plantation on peat of any depth for suppliers.

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

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

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

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

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

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

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

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

Evidence for best management practices for soil undertaken by the company is minimum soil cultivation, mosaic planting with native forests, maintenance of post-harvest waste, and the company states that it has no landbank on peat.

90. Commitment to reduced impact logging?

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

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

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

92. Evidence of implementing reduced impact logging practices?

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

93. Commitment to zero burning?

The company is committed to 'no burn' policy.

94. Commitment to zero burning applies to all suppliers?

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

95. Evidence of fire monitoring and management?

Points for external verification have been awarded on the basis of the company's PEFC certification. Also the company report in its 2019 sustainability report about the multi-pronged approach for monitoring fires which includes electronic surveillance, tactical ground patrol groups, awareness campaigns through the Friends of the Forest Program.

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

130 - In 2019, 49 fires were recorded for Bracell Sao Paulo operations and 81 for Bracell Bahia operations.

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

98. 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, and there's no target amount specified.

99. GHG emissions intensity?

The company reports total GHG emission as equal to 302,007 t of CO2 eq in 2019, specifiying which part is from forestry operations and which from industrial operations, however this is not expressed in intensity. A figure for Bahia operations is reported in intensity (0.817 kgCO2eq per kilogram of dissolving pulp) but a figure could not be found for São Paulo operations.

100. GHG emissions from land use change?

101. 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.

102. Methodology used to calculate GHG emissions?

GHG Protocol methodology.

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

The company has a 2019 time-bound commitment to improve use water intensity in 2020 to reach 23m3/TSA in its Sao Paulo operations. However, there is no target for the Bahia operations and the one set in 2018 was not met in 2019.

104. Water use intensity?

32.8 - For 2019, the company reports water use intensity for Bahia as 32.8 m³ per ton. Figures of water use at Sao Paulo are published but not given in intensity (6,194,388 m³).

105. Progress towards commitment on water use intensity?

[Externally verified] The company reports an increase in water use for both operations, from 31.2m3 per ton produced in 2018 to 32.8 m3 per ton produced in 2019 in the Bahia operations, and growing from 23.5m3 per ton produced in 2018, from a higher figure in 2019. Data has been verified with an assurance statement in the company's sustainability report.

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

The company had a target for 2019 but has not reported on it, and does not have another target for the future.

107. Progress towards commitment on water quality (BOD and 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. This information is however more than two years old.

108. Treatment of pulp and paper mill effluent?

[Externally verified] The company has effluent treatment stations for treating the pulp and paper mill effluent.

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

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

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

[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.

111. Commitment to protect natural waterways through buffer zones?

The company discuss the commitment towards riparian zones or protecting waterways in forest management plan for both the FMU unit.

112. 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.

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

The company has published this commitment.

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

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

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

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

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

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

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

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

Chemical usage for Bahia operations are included in a PEFC audit. However, this does not cover the full scope of operations, and is now more than two years old.

121. Implementation of commitment to reduce chemical usage?

122. Integrated Pest Management (IPM) approach?

Points for external verification have been awarded on the basis of the company's PEFC certification. As the International Standard's requirements do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator. The company also mentions its use of the Integrated Pest Management approach in its sustainability report, and FMPs.

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

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. The company also describes its waste management system in its FMPs and sustainability report.

124. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership. It also has its own commitment to the Universal Declaration of Human rights.

125. Commitment to human rights applies to all suppliers?

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

126. Progress on human rights commitment ?

[Externally verified] The company provides human rights training to its new employees and has an internal audit team which addresses the complaints pertaining to the violation of its code of conduct including protection of human rights. The evidence is verified by third party assurance.

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

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

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

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

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

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

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

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

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

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

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

134. 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. However, efforts have not been externally verified so full points cannot be awarded. The evidence is verified by third party assurance.

135. Details of process for addressing land conflicts available?

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

136. 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 the forestry operations. The evidence is verified by third party assurance.

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

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

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

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

139. Commitment to provide essential community services and facilities ?

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

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

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

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

The company makes this commitment in its sustainability report.

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

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

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

The company makes this commitment in its sustainability policy.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership and PEFC CoC certification.

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

[Externally verified] The company provides training to new employees on the code of conduct and has an internal audit team to address the matters in case any violations to the code are identified. The evidence is verified by third party assurance.

146. 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.

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

The company makes this commitment in its 2017 sustainability report.

148. 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. Similarly, it does not disclose information on the implementation of it's own commitment.

149. Percentage or number of temporary employees?

4,907 - In 2019, the company employed 4,097 temporary/contract workers.

150. Percentage or number of women employees?

19.74% - The company reports 16.82% of women in the Sao Paulo region and 22.65% of women in the Bahia region respectively.

151. Commitment to pay at least minimum wage?

The company makes this commitment in its latest Sustainability report.

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

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

[Externally verified] 27.4% - The company reports figures showing that it pays more than the minimum wage to its employees (lowest wage paid is 50.5%, 22.3% and 9.3% above the minimum wage in Bahia industrial unit, Sao Paulo, and the forestry unit respectively). The evidence is verified by third party assurance.

154. Reporting of salary by gender?

155. Commitment to address occupational health and safety?

The company has made a commitment to the ILO Declaration on Fundamental Principles and Rights at Work, but does not reference the ILO Code of Practice on Safety and Health in Forestry Work. The company also makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's PEFC CoC certification.

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

The company makes this commitment through the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's PEFC CoC certification.

157. Provision of personal protective equipment and related training?

[Externally verified] The company reports all staff are given PPE and provides examples of job specific safety training.

158. Time lost due to work-based injuries?

4 - The company reports accident frequency rates for its own and outsourced employees, in the forestry and industrial operations, and in Bahia and São Paulo regions (frequency rate = number or accidents x 1.000.000/ total man-hours worked). This averages around 4.

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

0 - The company reported 0 fatalities in 2018. Information of less than two years old could not be found.

160. 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 by sharing its forest technology and buying a part of their wood produced.

161. 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 by sharing its forest technology and buying a part of their woods produced. The evidence is verified by third party assurance.

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

152 - The company has respectively 44 and 108 farmers engaged in its smallholder programs in Sao Paulo and Bahia (Tree Farming Program). However, the figure for Bahia is more than three years old.

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

The company has a formal verification procedure but limited detail is provided on the process, hence, partial points are awarded.

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

[Externally verified] 100% - The company states that it assesses its suppliers on compliance with its requirements related to human rights, legality, labor practices and social commitments. Suppliers are regularly the subject of audits during the course of the relationship. The evidence is verified by third party assurance.

165. Suspension or exclusion criteria for suppliers?

The company's contracts require all suppliers to commit to respecting human rights, prohibit any form of discrimination, child labor, forced or slave-like labor and violations of freedom of labor unions, and support the right to collective bargaining. Supplier's contracts are revoked in case they do not abide by these requirements, however, the timeframe for action isn't stated.

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

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

168. Commitment to ethical conduct and prohibition of corruption?

The company adheres to its parent company's Code of Ethics, including ethical conduct and the prohibition of corruption.

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

One of the company's subsidiary has a code of ethics for purchases in place which applies to all the suppliers, but it does not apply to all the company's suppliers: suppliers to Sao Paulo are not included.

170. 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.

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

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

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

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

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

174. Whistleblowing procedure?

The company has a complaints policy which states maintaining anonymity and providing protection to whistleblowers, has established an internal audit department where inaccuracies can be reported.

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

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

176. Details of complaints and grievances disclosed?

The company has only disclosed the number of cases of grievances.