Eldorado Brasil Celulose SA

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

2. Sustainability policy or commitment applies to all sourcing?

The company has a code of conduct which applies to all its suppliers and includes social and governance policies in line with its sustainability policy. However, the policy does not cover environmental issues. Half a point has been awarded

3. High-level position of responsibility for sustainability?

The company has a Director in charge of Human Resources, Sustainability and Communication

4. One or more board members have responsibility for sustainability?

This indicator is disabled as the company is not publicly listed

5. Percentage or number of women board members?

This indicator is disabled as the company is not publicly listed

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

0 (0%)

7. Sustainability report published within last two years?

2,017

8. Member of multiple industry schemes or other external initiatives to improve forest management or transparency?

FSC

9. Activities with government, NGOs or academic institutions to improve the sustainability of forest products?

Participation in various stakeholder groups (e.g. local WWF Forums; IPEF, Forestry Studies and Research Institute)

10. Climate risks assessment available?

The company reports conducting research to predict potential impacts from climate change, however, no assessment/data has been published

11. Natural capital assessment available?

The company monitors water withdrawal at all withdrawal sites on its properties in accordance with water stewardship standards, however, it does not follow Natural Capital Protocol

12. Lists countries and operations?

Brazil (plantations, mill)

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

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests

14. Total area of forest plantation (ha)?

229,592 - The company reports having a production area of 229,592 ha out of a total landbank of 359,260 ha (figures published in 2018)

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

This indicator is disabled as the company has informed ZSL that it doesn't use outgrower schemes for wood/wood fibre production

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

17. Conservation set-aside and/or HCV area (ha)?

106,520 - The company's FSC surveillance report (last updated in April 2019) suggests that it has at least 106,519.72 ha conservation area. However this report does not cover all of the company's operations

18. Area of Intact Forest Landscape (ha)?

This indicator is disabled as the company has informed ZSL that it doesn't have any intact forest landscapes within its landbank

19. Number of Forest Management Units (FMUs)?

13

20. Maps of forest management units (FMUs)?

0.5 - The company only provides names of farms and a static map

21. Forest management plans available for all FMUs?

22. Monitoring of forest management plan implementation?

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

This indicator is disabled as the company's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

24. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

25. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

26. Number of company owned pulp and paper mills?

1 - The company is currently working on expanding the current mill (Vanguarda 2.0 project), but this is not yet operational

27. Maps or addresses of company owned pulp and paper mills?

28. Number of company owned sawmills?

This indicator is disabled as the company has informed ZSL that it doesn't own sawmills

29. Maps or addresses of company owned sawmills?

This indicator is disabled as the company has informed ZSL that it doesn't own sawmills

30. Number of supplier mills?

31. Maps or addresses of supplier mills?

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

The company has a FSC CoC certificate which counts as the procedure for the certified portion of all raw materials the company sources

33. Procedures to trace raw materials to FMU level?

The company has a FSC CoC certificate which counts as the procedure for the certified portion of all raw materials the company sources

34. Percentage of supply traceable to country level (above 80%)?

The company has CoC certificates covering its wood supply coming from the states of Mato Grosso do Sul and Goiás. However, it is unclear what percentage of all the company's supply that represents

35. Percentage of supply traceable to FMU level (above 75%)?

The company has CoC certificates covering their wood supply coming from the states of Mato Grosso do Sul and Goiás. However, it is unclear what percentage of all the company's supply that represents

36. Commitment to zero conversion of natural forest?

37. Zero conversion commitment applies to all sourcing?

38. Commitment to minimise the impact of logging roads?

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests

39. Commitment to protect forest areas from illegal activities?

40. Evidence of monitoring deforestation?

The company states that drones are monitoring an average 500 hectares daily to indentify environmental damage and erosion and the data is fed into a system that builds a 3D model of the company's land (incl. conservation areas)

41. Amount of deforestation recorded?

42. Commitment to biodiversity conservation?

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

44. Implementing a landscape-level approach to biodiversity conservation?

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

46. Commitment to sustainably manage the use of non-timber forest products (NTFPs)?

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests

47. Commitment not to use genetically modified organisms?

The company has committed to not be directly or indirectly involved in the introduction of genetically modified organisms in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004)

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

49. HCV commitment applies to all sourcing?

The company has a commitment to only source wood/wood fibre that meets FSC Controlled Wood requirements which includes not sourcing wood from forests with a high conservation value

50. Commitment to only use licensed High Conservation Value (HCV) assessors accredited by the HCV Resource Network's Assessor Licensing Scheme (ALS)?

This indicator is disabled until sufficient number of HCV ALS licensed assessors are available for the location where the company operates

51. High Conservation Value (HCV) assessments available?

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

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

54. High Carbon Stock (HCS) assessments available?

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

56. Social and environmental impact assessments (SEIAs) available?

The company has provided some information on its Environmental Impacts EIA, however no information on Social Impacts is available

57. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

58. Commitment to best management practices for soils and/or peat?

59. Commitment to reduced impact logging?

This indicator is disabled as the company has informed ZSL that it only produces wood/wood fibre from plantation forests

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

This indicator is disabled as the company has informed ZSL that it doesn't have landbank on peat

61. Commitment on peatland planting applies to all sourcing?

This indicator is disabled as the company has informed ZSL that it does not have suppliers with landbank on peat

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

This indicator is disabled as the company has informed ZSL that it doesn't have landbank on peat

63. Evidence of best management practices for soils and/or peat?

64. Commitment to zero burning?

65. Commitment to zero burning applies to all sourcing?

66. Evidence of management and monitoring fires?

67. Details/number of hotspots/fires in FMUs controlled by the company?

68. Time-bound commitment to reduce GHG emissions intensity?

69. Progress towards reducing GHG emission intensity?

0.16 - Company reports progress towards reducing GHG intensity but no target in place

70. Report GHG emissions from land use change?

71. Methodology used to calculate GHG emissions?

Brazilian GHG Protocol

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

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

The company has no commitment in place but reports that it reduced BOD by 97.4% in 2017

74. Commitment to protection of natural waterways through buffer zones?

75. Evidence of treatment of pulp and paper mill effluent?

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

This indicator is disabled as the company has informed ZSL that it doesn't own sawmills

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

78. Progress towards commitment on water use intensity?

25,711.6 - The company reports reduction in the amount of water consumption intensity (m3/ADT) in 2017 compared to 2016 and 2015. However there is no time-bound commitment in place to reduce water use

79. Commitment to eliminate chlorine and chlorine compounds for bleaching?

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

81. No use of World Health Organisation (WHO) Class 1A and 1B pesticides?

82. No use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

83. Integrated Pest Management (IPM) approach?

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

Figures for pesticides and herbicides used can be found in 2017 FSC Audit Report, however this report does not cover all of the company's operations (i.e. some FMUs are excluded from certification)

85. Commitment to human rights, referencing the UN Declaration on Human Rights or UN Guiding Principles on Business and Human Rights?

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights

86. Commitment to human rights applies to all sourcing?

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which defines human rights as those established through the UN Declaration of Human Rights

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

The company has committed to not be directly or indirectly involved in the violation of human rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which encompasses the rights of Indigenous and Tribal Peoples as established by the ILO Convention 169

88. Commitment to respect legal and customary property rights?

The company has committed to not be directly or indirectly involved in the violation of traditional rights in forestry operations. This commitment is made through the FSC Policy for Association (FSC-POL-01-004), which encompasses customary rights. This policy does not reference legal rights and no reference to legal rights could be found in company sources

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

90. FPIC commitment applies to independent suppliers?

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

92. Examples of local stakeholder engagement to prevent conflicts?

93. Details of process for addressing land conflicts available?

94. Commitment to support the inclusion of women across forestry operations, including addressing barriers faced?

95. Commitment to provide essential community services and facilities?

96. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

97. Commitment to respect all workers' rights?

98. Reference to Fundamental ILO Conventions?

The company has committed to not be directly or indirectly involved in the violation of any of the ILO Core Conventions. This commitment is made through the FSC Policy for Association (FSC-POL-01-004)

99. Commitment to eliminate gender related discrimination with regards to employment and occupation?

100. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

101. Percentage or number of temporary employees?

0 (0%) - The company reports having no temporary employees as of 2017

102. Percentage or number of women employees?

582 (15.3%)

103. Payment of minimum wage?

104. Reporting of salary by gender?

105. Commitment to address occupational health and safety, referencing the ILO Code of Practice on Safety and Health in Forestry Work?

The company commits to address occupational health and safety but no reference to the ILO Code of Practice on Safety and Health in Forestry Work given

106. Time lost due to work-based injuries?

620 - Figure relates to number of days lost due to occupational injuries

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

0

108. Provision of personal protective equipment and related training?

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

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

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

350,826 (97.65%) - The company reports it operates on 359,260.46 ha land (incl. conservation areas) and has 350,826.49 ha of Forest Area that is FSC-FM/CoC certified. This represents 97.65% of the total forest area controlled by the company (figures published in 2017 and 2018)

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

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

114. Commitment to source only wood/wood fibre that meets FSC Controlled Wood requirements?

115. Percentage area (ha) FSC FM certified?

350,826 (97.65%) - The company reports it operates on 359,260.46 ha land (incl. conservation areas) and has 350,826.49 ha of Forest Area that is FSC-FM/CoC certified. The represents 97.65% of the total forest area controlled by the company (figures published in 2017 and 2018)

116. Percentage of wood/wood fibre supply from outgrower scheme and/or independent suppliers that is FSC FM certified?

117. Percentage of all wood/wood fibre supply traded/processed that are FSC certified (above 75%)?

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

The company states that the majority of its area is certified by Cerflor. However, it is not possible to accurately calculate the percentage area PEFC certified, that is not FSC certified

119. Programme to support outgrower scheme smallholders?

This indicator is disabled as the company has informed ZSL that it doesn't use outgrower schemes for wood/wood fibre production

120. Percentage of outgrower scheme smallholders involved in programme?

This indicator is disabled as the company has informed ZSL that it doesn't use outgrower schemes for wood/wood fibre production

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

122. The company has a Due Diligence System (DDS)?

123. Suspension or exclusion criteria for suppliers?

124. Percentage of suppliers assessed and/or engaged on compliance with company requirements?

172 - Figure represents new suppliers in 2016 that were assessed by the company. Additionally, the company states that 3,000 suppliers were assessed in 2015

125. Commitment to ethical conduct and prohibition of corruption?

126. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

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

128. 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's reporting broadly suggests that it doesn't operate in a geography currently covered by Open Timber Portal. Please note that ZSL has been unable to confirm this

129. Whistleblowing procedure?

The company has an external Ombudsman channel which allows for anonymity. However, no clear description of the steps taken could be identified

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

131. Details of grievances disclosed?

The company provides a summary of the grievances in 2017 and states their status