CENIBRA

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

The company has a sustainability policy and Compliance policy, which seeks to facilitate the incorporation of economic, social, and environmental aspects into its business strategies.

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

3. High-level position of responsibility for sustainability?

Industrial and Technical Director is incharge of the technical management of industrial and forestry processes.

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 - The company report no women were part of senior management team.

6. Percentage or number of women board members?

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] FSC.

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

The company partners with beekeepers associations to install beehives, and this project has a significant social, economic, and environmental effect because it provides new employment and income to beekeepers and their families while still protecting the environment. The company Institute, Unileste (University Center of Eastern Minas Gerais), and the Women's Association of Periquito's So Sebastio do Baixo District collaborate to improve and formalise group interaction and learning, as well as promote the organisation of institutions involved in job and income generation for families in this city and its environment.

9. Sustainability report published within last two years?

Sustainability Report 2019.

10. Reports through standardised reporting systems?

The report is prepared in accordance with GRI standards and has also published on GRI database.

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

Single pulp mill with two bleached short-fiber eucalyptus pulp production lines and three regional forest stewardship units in the state of Minas Gerais, Brazil.

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)?

129054 - Eucalyptus plantation. Figure as of 2021 and exclusive of outgrower areas.

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

22894.3 - The total area within outgrower scheme is 22894,34 hectares.

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

55.88 - The company states that 55.88 hectares of land is available for plantation and also reports 6,809.80 ha land as being on stand-by and it is unclear if this area should also be counted towards unplanted area.

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

105874 - Legal Reserves and Permanent Preservation areas and native vegetation.

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)?

3 - The company states that there are three regional forest stewardship units.

22. Maps of forest management units (FMUs)?

The company only provides a static map of its FMUs.

23. Forest management plans available for all FMUs?

24. Monitoring of forest management plan implementation available?

[Externally verified] The company monitors the impacts of its activities on the environment and on the communities in its areas of operation in order to bring improvements in management and activities. Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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 discloses the name of suppliers, however, no information is available regarding the supplier location.

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?

1 - The company has only one pulp mill.

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

The company has only one pulp mill located in Belo Oriente, MG.

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?

In 2020, 81.23% of supply was from the company's own operations and 18.77% purchased from third-parties.

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 published "Traceability of CENIBRA Product" which states that each timber transported by truck or train is monitored by the NTM (Timber Transport Note), inserted in the information system of CENIBRA SAP.

39. Percentage of supply traceable to country of harvest?

100 - The company states that all of its supply comes from Minas Gerais, Brazil therefore supply is traced back to country level.

40. Procedures to trace raw materials to FMU level?

The company has published "Traceability of CENIBRA Product" which states that each timber transported by truck or train is monitored by the NTM (Timber Transport Note), also states that Annual forest management (FM) and chain of custody (CoC) audits are carried out to validate the information.

41. Percentage of supply traceable to FMU level?

The company states that 83% of its supply comes from its own plantations and the remaining 17% can be traced back to the source.

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?

98% - FSC certification.

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

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

81.34% - The company states that 83% of its supply comes from its own plantations which are 98% FSC certified therefore percentage of supply that is legality verified can be calculated (83 x0.98 = 81.34%).

46. Percentage area (ha) FSC FM certified?

98% - Percentage calculated based on plantation area.

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

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

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

The company published its wood procurement policy which states that company only purchase woods from forest areas where the applicable legal requirements are complied with.

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

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.

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) 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.

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?

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?

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications 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 states the priority of biodiversity conservation and protection.

62. Commitment to biodiversity conservation applies to all suppliers?

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

[Externally verified] The company has also identified species of conservation concern referring IUCN Red list. Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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

The company also mentions preserving the environmental quality of forests and lands ensures the sustainability of its business. Points for external verification have been awarded on the basis of the company's FSC/PEFC certified landbank/volume (whichever is highest).

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

The company commits to illegal hunting and provide property security.

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

67. Commitment to protect forest areas from illegal activities?

The company monitors illegal activities such as hunting or fishing to protect its property and preservation area for future use.

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

69. Evidence of protecting forest areas from illegal activities?

The company states in its sustainability report about the training courses, interpretative visits, and recreational activities to enhance awareness of the importance of wildlife and vegetation conservation and the sustainable use of natural resources. Points for external verification have been awarded on the basis of the company's FSC/PEFC certified landbank/volume (whichever is highest).

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) 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.

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

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.

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?

HCV assessment is available for the companies FSC certified FMU in the forest stewardship plan published by the company. This does not cover the company's entire operational area.

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

HCV management and monitoring plans are available for the companies FSC certified FMU in the forest stewardship plan published by the company. This does not cover the company's entire operational area.

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?

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

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

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

81. Social and environmental impact assessments (SEIAs) available, and associated 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?

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

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

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

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

The company commits to maintain soil quality by following strict guidelines in its properties (projects forestry).

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

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

Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria with regards to peatlands, limited, externally verified points have therefore been awarded for this indicator.

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?

94. Commitment to zero burning applies to all suppliers?

95. Evidence of fire monitoring and management?

The company also reports about conducting Campaigns and Educational Activities, Training and Capacity Building, help in Risk Identification, Fire Service Maintenance, and help to know about Fire Detection. Points for external verification have been awarded on the basis of the company's PEFC certification.

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

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

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

99. GHG emissions intensity?

The CO2 Emissions - Carbon Dioxide for the year 2019 is 2,938 kg/ADt. However, the figure is not specific to forestry operations.

100. GHG emissions from land use change?

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

101. Progress towards commitment to reduce GHG emissions intensity?

The company reports improvement in CO2 Emissions intensity figures - Carbon Dioxide (kg/ADt): 2017 (3,116), 2018 (3,377) and 2019 (2,938). However, the figure is not specific to forestry operations.

102. Methodology used to calculate GHG emissions?

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

104. Water use intensity?

37.74 - The company reports a water use intensity of 37.74 m³/ADt for the year 2019. However, the figure is not specific to forestry operations.

105. Progress towards commitment on water use intensity?

The company reports yearly specific water intake figures in m³/ADt as: 41.52 (2017), 39.28 (2018), and 37.74 (2019), which is reducing every year. However, the figure is not specific to forestry operations.

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

The company commits to monitor liquid effluents to ensure they are in compliance with legal limits (BOD target: 60 mg O2/l; COD target: 353 mg O2/l). However, these targets are not time-bound and monitoring frequency is not indicated.

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

The company reports Chemical Oxygen Demand (kg/ADt): 8.65 (2017),  9.47 (2018), and 10.51(2019) and BOD5 (Biochemical Oxygen Demand) (kg/ADt): 0.87 (2017),  1.01 (2018) and 1.09 (2019). From the following figure it is clear that there is no improvement in water quality.

108. Treatment of pulp and paper mill effluent?

The company monitors its liquid effluents to ensure they are disposed in line with the applicable legislation (limits of emission and water body quality change).

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?

111. Commitment to protect natural waterways through buffer zones?

The company is an important water producer and also protects waterways but it is unclear if waterways are protected across all of the company's operations.

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

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications 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?

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?

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?

Company has provided information only for sodium hydroxide and quicklime used in the pulp mill, not for pesticides and chemical fertilisers.

121. Implementation of commitment to reduce chemical usage?

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

122. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

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.

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 ?

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 PEFC International Chain of Custody Standard (PEFC ST 2002:2013). Full points have therefore been awarded on the basis of the company's PEFC CoC certification.

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?

Points for external verification have been awarded on the basis of the company's FSC certification. As the P&Cs do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

135. Details of process for addressing land conflicts available?

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

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 states that it provides numerous prospects for local social and economic advancement, employment and income production, skilled qualification, and funding for a variety of services in the fields of schooling, community, athletics, and others.

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

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

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

The company has published this commitment.

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 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.

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

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

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

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

149. Percentage or number of temporary employees?

3252 - The company reported total outsourced personnel to be 3,252.

150. Percentage or number of women employees?

436 (9.09%) - Figures do not cover all employees.

151. Commitment to pay at least minimum wage?

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

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

The company reports its entry level wage as 1,142, and local minimum wage to be 998 for year 2019. The figure reported for companies significant location of operation.

154. Reporting of salary by gender?

155. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

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

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004) and the PEFC International Chain of Custody Standard (PEFC ST 2002:2013). As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC/PEFC CoC certification.

157. Provision of personal protective equipment and related training?

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC/PEFC certification. As the requirements of these certifications do not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded for this indicator.

158. Time lost due to work-based injuries?

5 - The company reported five lost time work accidents for the year 2019, resulting in a 0.54 frequency rate.

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

160. Commitment to support smallholders?

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

The company Forestation Incentive Program for Farmers brings farmers into the Company's production chain as wood suppliers. Aiming to strengthen the role of economic, social, and environmental development agent in the regions where it operates.

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

651 - The company in its Sustainability Report states that currently, it supports 651 farmers as a part of its Forestation Incentive Program.

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

The company discloses in its sustainability report about qualification program which aims at providing evidence that the supplier complies with quality requirements which also covers legal aspects, tax and labor compliance, and the supplier's economic, financial, and technical capabilities.

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

51 - The company evaluated 51 suppliers through integrated auditing and did not identify significant negative impacts.

165. Suspension or exclusion criteria for suppliers?

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 values ethical and moral principles in its relations and respects the laws and regulations applicable to its business.

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

The company's sustainability report ensures its suppliers to follow code of conduct.

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

The company mention in its sustainability report that its Internal Audit department is responsible for evaluating non-conformities and internal processes and if the code of ethics criteria is in line to mitigate the occurrence of any violation. In 2019, the company expanded resources available on ethical practices to employees and updated its Code of Ethics.

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 whistleblowing procedure is applicable for overall operations.

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

The company follow proper communication channel to file complaints which is open to all stakeholders.

176. Details of complaints and grievances disclosed?

The company's sustainability report states that no complaints were registered in 2019 to the pulp and paper industry.