Celulose Irani SA

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

The company has its own sustainability policy which states it conserves and preserves the environment.

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

3. High-level position of responsibility for sustainability?

The company reports it has established a 'Sustainability Committee' comprising the Executive Board, and Business & Corporate Managers with the responsibility of ensuring evolution and strategic alignment, however, it is unclear which position has high-level responsibility.

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

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

0 - Gender balance is not directly reported by the company, but is identified from the 'Board of Executive Officers' profile photos reported in the company's 'Integrated Report' 2021.

6. Percentage or number of women board members?

0 - The company reports that its Board of Directors is composed of 5 members, all of whom are men.

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 only a member of the UNGC.

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

The company reports a partnership with the state government under the 'RS BIODIVERSITY' project conducting a rapid ecological assessment (REA) at one of company's locations to identify preservation areas, and establish management and monitoring measures to curb illegal activities and promote conservation of biodiversity. The company formed a partnership with Embrapa Florestas to carry out a study of the black-horned capuchin. The company also collaborates with Concordia Environmental Military Police (SC) for forest security.

9. Sustainability report published within last two years?

The company's latest integrated report was published in 2022, covering the year 2021.

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for Climate Change, Forests, and Water Security in 2022.

11. Climate risks assessment available?

[Externally verified] The company has only identified limited impacts of climate change on its operations in selective categories. The information reported is externally assured by KPMG, however, no information is reported on metrics, targets, and processes used to assess or manage climate risks.

12. Natural capital assessment available?

13. Lists countries and operations?

The company has eucalyptus and pine forest concessions in Santa Catarina and Rio Grande do Sul, and papers are produced in the Paper SC Campina da Alegria (Vargem Bonita-SC) and Paper MG (Santa Luzia-MG) paper units.

14. Lists countries sourcing from?

The company reports it sources from local suppliers in Brazil as well as imports from other countries. However, the source of origin for imported supply is not reported.

15. Total land area managed/controlled for forestry (ha)?

33899.5 - The company reports a total of 33,899.48 ha of land, of which 82.4% (27,900 ha) is in the state of Santa Catarina and 17.6% in Rio Grande do Sul (5,952.32 ha). Figures include areas destined for infrastructure and a reservoir.

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

33899.5 - The company reports a total of 33,899.48 ha of land, of which 82.4% (27,900 ha) is in the state of Santa Catarina and 17.6% in Rio Grande do Sul (5,952.32 ha).

17. Total area of forest plantation (ha)?

16386.2 - The company reports a total of 33,899.48 ha of land, of which 12,400 ha are planted forests in the state of Santa Catarina and 3,986.19 ha are planted in Rio Grande do Sul. The figures exclude the outgrower scheme areas.

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

0

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

0

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

3150 - The company reports a total High Conservation Value area of 3,150 ha.

21. Area of Intact Forest Landscape (ha)?

0

22. Number of Forest Management Units (FMUs)?

2 - The FSC public summary report and the integrated report 2021 of the company disclose two FMUs (Santa Catarina and Rio grande do sul - Habitasul Florestal S.A.) controlled by the company.

23. Maps of forest management units (FMUs)?

The company has only disclosed a static forest map of its operations and the FSC report only has a map for the company's one FMU.

24. Forest management plans available for all FMUs?

The forest management plans for both (Santa Catarina and Rio Grande Do Sul) concessions of the company are publicly available.

25. Monitoring of forest management plan implementation available?

[Externally verified] The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified). The forest management plans published by the company for its two FMUs have very limited details on monitoring performance against FMP objectives.

26. 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.

27. 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.

28. 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.

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

30. Number of company owned sawmills?

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

31. Names and locations of company owned sawmills?

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

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

2 - The company reports it has a factory with four paper machines, located in Vargem Bonita SC (Paper SC Campina da Alegria) and a factory with a paper machine in Santa Luzia - MG (Paper MG Santa Luzia).

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

The integrated report 2021 of the company reports two paper factories; Paper SC Campina da Alegria and Paper MG Santa Luzia. A static image without coordinates is reported by the company for both paper factories.

34. 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.

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

36. Number of third party supplying mills?

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

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

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria.

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not fully meet the SPOTT scoring criteria.

42. Percentage of supply traceable to FMU level?

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

The company is 100% legality verified by FSC for FM and COC since 2008.

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

[Externally verified] 100% - 36,318.03 ha is verified as being legally compliant by FSC since 2008.

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

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

47. Percentage area (ha) FSC FM certified?

100% - The company reports it has been 100% FSC FM/COC certified since 2008.

48. Time-bound plan for achieving 100% FSC FM certification of FMUs within 10 years?

The company is 100% FSC FM certified since 2008.

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

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

The company commits to only source wood/wood fibre that meets FSC Controlled Wood requirements.

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

52. Commitment to zero conversion of natural ecosystems?

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

54. Commitment to zero deforestation?

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.

55. Commitment to zero deforestation applies to all suppliers?

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

57. Criteria and cut-off date for defining deforestation in supplier operations?

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

The company reports monitoring and surveillance of its areas are carried out by its own team and with support from a contracted company for controlling access, restricting predatory actions against fauna and flora, and preventing damage to forest plantations. However, the methodology, extent of the area being monitored for deforestation and ecosystem conservation, and timeframe are not reported.

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

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

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

62. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

63. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2 EN). As the Standard does not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded.

65. Biodiversity policy?

66. Biodiversity policy applies to all suppliers?

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

[Externally verified] The company has identified species of conservation concern, referencing the Red List of the International Union for Conservation of Nature system of species classification. This information is externally verified by KPMG.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. The company also reports multiple examples of habitat conservation management.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

71. Commitment to protect forest areas from illegal activities?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

73. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria.

74. 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.

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

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

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

78. High Conservation Value (HCV) assessments available?

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

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

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

82. High Carbon Stock (HCS) assessments available?

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

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

87. 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.

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

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

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

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

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

The company makes this commitment for soil only through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

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

Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports a few examples of management practices to conserve soils in its FM plan for Santa Catarina.

95. Commitment to reduced impact logging?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

97. Evidence of implementing reduced impact logging practices?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

98. Commitment to zero burning?

99. Commitment to zero burning applies to all suppliers?

100. Evidence of fire monitoring and management?

The company reports it has a fire detection and monitoring system installed as part of the surveillance system. For the management of fires, the company's surveillance structure provides specific flame-retardant equipment and clothing, as well as a fire truck. The company also established an Emergency Brigade and mapped water abstraction points and signed an agreement with the Irani Voluntary Fire Department and has an active annual training schedule. Such actions have guaranteed excellent fire combat results during outbreaks, and also in responding to emergencies. This information is externally assured by KPMG.

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

3 - Three fire outbreaks were recorded in 2021.

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

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

104. GHG emissions intensity?

The company reports GHG intensity figures for all its operating units for the year 2021.

105. GHG emissions from land use change in company's own operations (scope 1)?

The company reports scope 1 emissions as 41,826 tons of CO2EQ in 2021.

106. GHG emissions from land use change in supplier operations (scope 3)?

The company reports scope 3 emissions as 10,955 tons of MGCO2EQ in 2021.

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports intensity for all operating units. However, the intensity for a few units has increased in 2021 as compared to the intensity reported in previous years, considering the baseline year as 2013. Also, it is unclear if the information reported is externally verified.

108. Methodology used to calculate GHG emissions?

The company reports that the measurements for quantifying greenhouse gas emissions are based on international standards developed by the International Organization for Standardization (ISO 14064) and the World Resources Institute (WRI), covering all direct Emissions (Scope 1) and Indirect Emissions from the Consumption of Energy (Scope 2), as well as Indirect Emissions from other Sources (Scope 3).

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

The company commits to reducing water use intensity by 30% by the year 2030.

110. Water use intensity?

10.97 - The company reports water use intensity figures for all of its operating units for the year 2021.

111. Progress towards commitment on water use intensity?

The company reports its water use intensity for all operating units and mentions a 7% reduction in water use intensity in 2021. However, it is unclear if the information reported is externally verified.

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

The company only reports that all its units comply with the legal parameters established by Conama Resolution 430/2011. A clear time-bound commitment to improving water quality (BOD/COD) is not reported.

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

The company reports that all its units comply with the legal parameters established by Conama Resolution 430/2011 and there were no incidents of noncompliance associated with permits, standards, or water quality regulations. However, the company does not report figures or specify the legal limits.

114. Treatment of pulp and paper mill effluent?

[Externally verified] The company reports that the effluents from production processes, cleaning of equipment, draining of tanks, and cooling water are treated to remove solid materials and stabilise dissolved organic matter, prior to returning the water to its source, into a freshwater course. This information is externally assured by KPMG.

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

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

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

The company reports that one of its paper units Paper MG Santa Luzia uses a closed circuit. However, it is unclear if the information reported is externally verified.

117. Commitment to protect natural waterways through buffer zones?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percentage of company landbank certified by FSC.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

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

127. Implementation of commitment to minimise inorganic fertiliser usage?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

128. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

[Externally verified] The company has a waste management system in place to avoid negative impacts. This information is externally assured by KPMG.

130. Commitment to human 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. The company also reports its own commitment to human rights principles as part of being a UN Global Compact member.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

133. 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.

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2) and PEFC International Standard (PEFC ST 1003:2018). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

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

140. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

141. Details of process for addressing land conflicts available?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

[Externally verified] The company only reports limited examples which include training women employees to assume roles in operation and leadership teams. The information reported is externally assured by KPMG.

143. 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.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

145. Commitment to provide essential community services and facilities ?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified). The company also reports its own commitment to providing essential community services and facilities.

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of the company landbank certified by FSC. The company's own reporting is very limited.

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

The company reports a commitment to providing business/work opportunities for local communities.

148. 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.

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

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.

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

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

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

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

The company considers discrimination based on gender, age, religion, sexual orientation, political conviction, and/or disability as a punishable conduct.

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

The company considers discrimination based on gender, age, religion, sexual orientation, political conviction, and/or disability as a punishable conduct. This commitment applies to all suppliers.

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

[Externally verified] Limited, externally verified points have been awarded on the basis the company's landbank is either 100% or >75% (and a further commitment to be 100% certified within 5 years) FSC FM certified (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

155. Percentage or number of temporary employees?

24 (1%) - The company reports a total of 24 employees with the CLT - fixed contract in 2021.

156. Percentage or number of women employees?

377 (17%) - The company reports a total of 377 women employees in 2021.

157. Commitment to pay a living wage?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

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

159. Progress on commitment to pay a living wage?

[Externally verified] Limited, externally verified points have been awarded on the basis that the company's landbank is either 100% or >75% (and a further commitment to be 100% certified within 5 years) FSC FM certified (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

160. Reporting of salary by gender?

The company reports the proportion of wages paid to men and women in line with GRI reporting.

161. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). Full points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified). The company also reports its own commitment to addressing occupational health and safety, however, it does not refer to the ILO Code of Practice on Safety and Health in Forestry Work.

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

The company commits its suppliers to address occupational health and safety, however, it does not refer to the ILO Code of Practice on Safety and Health in Forestry Work.

163. Provision of personal protective equipment and related training?

Limited, externally verified points have been awarded on the basis of the company's FSC Chain of Custody (FSC-STD-40-004 V3-1) and FSC FM (FSC-STD-01-001 V5-2) certifications as the requirements do not fully meet the SPOTT indicator criteria.

164. Time lost due to work-based injuries?

38 - The company reports 38 accidents and a rate of lost time injuries of 11.07 in 2021.

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

0 - The company reports zero fatalities in 2021.

166. Commitment to support smallholders?

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

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

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

The company reports it applies the evaluation that measures the Supplier Performance Index for the five purchasing groups.

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

520 - The company reports the number of suppliers and service providers evaluated in 2021 as 520. However, it is unclear if this information is externally verified.

171. Suspension or exclusion criteria for suppliers?

The company reports it applies evaluation that measures the Supplier Performance Index to the five purchasing groups. Measured from 0 to 100 points, for suppliers below 60 points, registration is canceled and contracting or purchases are not possible. The requalification can be requested from the moment the supplier/service provider meets the applicable requirements and presents an action plan approved by the company's supply or forestry manager, depending on the type of service provided.

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

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

174. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the prohibition of corruption.

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

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

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

[Externally verified] The company reports it has an ethics committee, whose role is to oversee, promote and disclose the conduct presented in the Code of Ethical Conduct, in addition to training and guiding the managers and employees. An ethics channel is also in place to raise complaints. This information is externally assured by KPMG.

177. 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.

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

179. 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.

180. Whistleblowing procedure?

The company only states that situations that characterise a violation of its 'Code of Conduct' must be reported and guarantees the confidentiality, and anonymity of the person making the manifest and also states to protect the person from retaliation. However, details on the whistleblowing procedure are not reported.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-STD-01-001 V5-2). As the requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC-certified landbank (100% certified).

182. Details of complaints and grievances disclosed?