Celulose Irani SA

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

The company has published a sustainable forestry policy which covers all operations.

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

3. High-level position of responsibility for sustainability?

The company reports it has a 'Sustainability Committee' associated with the Executive Board, responsible for reviewing the economic and socioenvironmental topics linked to the business, however, it is unclear which position has the high-level responsibility.

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

5. Reports gender balance of senior management team?

0 - The company does not directly report gender balance but the company's Integrated Report 2022 states the profile of Executive Officers along with photographs.

6. Reports gender balance of 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 to collaborate with government agencies and academic institutions, like participating in the PPPIB with IPEF, Udesc, a Wild Boar Project with EMBRAPA Suínos and a partnership with the Rio Grande do Sul government under the RS Biodiversity project, the company conducted a Rapid Ecological Assessment in one location.

9. Sustainability report published within last two years?

The company's latest integrated report was published in 2022.

10. Reports through standardised reporting systems?

The company has submitted CDP questionnaires for Climate Change, Forests, and Water Security in 2023.

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

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

14. Lists countries sourcing from?

The company reports it sources from local suppliers in Brazil as well as global suppliers. However, the source of origin for these global suppliers 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 (5,926.55 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 (5,926.55 ha).

17. Total area of forest plantation (ha)?

16312.2 - 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 3,912.22 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)?

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

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)?

22. Number of Forest Management Units (FMUs)?

2 - The company reports that it has two FMUs, located in Santa Catarina and Rio grande do sul (Habitasul Florestal S.A.).

23. Maps of forest management units (FMUs)?

24. Forest management plans available for all FMUs?

The company reports forest management plans for both Santa Catarina and Rio Grande Do Sul concessions.

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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 does not operate in a country 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 does not operate in a country 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 does not operate in a country currently covered by Open Timber Portal.

29. Maps 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 any sawmills.

31. Names and locations of company owned sawmills?

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

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

2 - The company reports it has a factory 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 company reports two paper factories namely Paper SC Campina da Alegria and Paper MG ? Santa Luzia and provides a static map without coordinates for both 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 any 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 full 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?

100% - 36,313.2 ha is verified as being legally compliant by FSC.

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 to be 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.

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)?

This indicator is disabled as the company is 100% FSC FM certified.

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 V3-0). 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 conducted jointly by the organization's own team and a contracted company, focusing on controlling access, preventing harm to wildlife and vegetation, and safeguarding forest plantations. However, the methodology, monitored area extent, 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 reports identifying species of conservation concern, according to 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.

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 V3-0). 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 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 does not operate in a country 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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.

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 having a surveillance system including a fire detection and monitoring system. It provides flame-retardant gear, a fire truck, and an Emergency Brigade, designed to provide effective fire management. This information is externally verified by KPMG.

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

3 - Three fire outbreaks were recorded in 2022.

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 greenhouse gas emissions intensity data for all its operational units, comprising Scope 1, 2, and 3 emissions.

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

The company reports scope1 emissions as 43,255 tons of CO2EQ in 2022.

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

The company reports scope 3 emissions as 9,143 tons of MGCO2EQ in 2021.

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports intensity for all operating units with some units experiencing an increase in 2022 compared to previous years, using 2013 as the baseline.

108. Methodology used to calculate GHG emissions?

The company reports that the measurements for quantifying greenhouse gas metrics are based on ISO 14064 and WRI standards, covering Scope 1, Scope 2, and Scope 3 emissions.

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?

10.65 - The company reports water use intensity figures for all of its operating units for the year 2022.

111. Progress towards commitment on water use intensity?

The company reports a 1.5% reduction in specific raw water use in 2022.

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

The company only reports that its units comply with the legal parameters established by Conama Resolution 430/2011, Consema 181/2021, Joint Normative Resolution COPAM/ CERH-MG No. 1/2008 and State Decree No. 8468/1976, article 19 but a clear time-bound commitment for improving water quality (BOD/COD) is not reported.

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

The company reports a reduction in the specific volume of effluent (m³) per net ton produced for 2022 as compared to 2021 but 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 stabilize dissolved organic matter, before returning the water to its source, into a freshwater course and different treatment methods like Biological (prolonged aeration), Sanitary: Biological Industrial: Physical Chemical/Biological and the 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 any sawmills OR only trades wood/wood fibre.

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

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 percent 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 reports having a waste management system. This information is externally verified by KPMG.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

133. Commitment to respect Indigenous Peoples' and local communities' rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

134. Commitment to Indigenous Peoples' 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). Full points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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) and PEFC International Standard (PEFC ST 1003:2018). Full points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

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

[Externally verified] The company only reports limited examples including training women employees to promote the expansion of awareness, and leveraging possibilities for women's performance, career and personal and professional development. This information is externally verified 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 does not operate in a country 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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 company landbank certified by FSC.

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

The company reports contributing to the generation of employment and income in the surrounding 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 does not operate in a country 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 V3-0). 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 reports 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 reports discrimination based on gender, age, religion, sexual orientation, political conviction, and/or disability as a punishable conduct and the 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?

156. Reports gender balance of employees?

517 (22.32%) - The company reports a total of 517 women employees in 2022.

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 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years.).

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

The company's commitment to address occupational health and safety applies to all suppliers but 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?

25 - The company reports 25 accidents and a lost time injury rate of 7.99 in 2022.

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 non-smallholder suppliers on compliance with company's policy and/or legal requirements?

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

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

647 - The company reports the number of suppliers and service providers evaluated in 2022 as 647 but it is unclear if this information is externally verified.

171. Suspension or exclusion criteria for suppliers?

The company reports having an evaluation process to assess the Supplier Performance Index across its five purchasing groups. The registration of suppliers may get cancelled if they score below 60 points, preventing further contracting or purchases. Requalification is possible upon meeting requirements and presenting an approved action plan to the relevant supply or forestry manager.

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

173. Proportion of supply from suppliers that is verified as deforestation and/or conversion-free (DCF)?

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, and has established a procedure for denunciations. The company hired a specialized outside firm to manage the system, with anonymity assured a total of 89 communications was received. 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 does not operate in a country 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 does not operate in a country 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 confidentiality and a procedure for denunciations through its Ethics Channel. This channel is available to receive communications from employees, suppliers and other stakeholders. 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 (either 100% or ?75% and a further commitment to be 100% certified within 5 years).

182. Details of complaints and grievances disclosed?