Eldorado Brasil Celulose

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

The company has its own sustainability policy applicable throughout its operations.

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

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.

3. High-level position of responsibility for sustainability?

The company has a director who is responsible for Human Resources, Sustainability, and Communication.

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?

1 - Gender balance not directly reported. The company only provides the names of members of the executive management team.

6. Percentage or number of women board members?

0 - The company reports there are no 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] The company is a member of FSC and UNGC.

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

The company is working in local partnerships, runs various projects and initiatives in education and environmental conservation in the communities in the region. (e.g Eldorado Sustainability Program, Friends of the Environment, Sustainable Homes, Clean Oil Program & Friends of Eldorado (AME), etc.).

9. Sustainability report published within last two years?

Sustainability Report 2019.

10. Reports through standardised reporting systems?

Global Reporting Initiative (GRI) Standards.

11. Climate risks assessment available?

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

12. Natural capital assessment available?

13. Lists countries and operations?

Brazil (plantations, mill).

14. Lists countries sourcing from?

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)?

230990 - The company reported a total production area of 230,990 hectares.

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

This indicator is disabled as the company reports that it does not source from outgrower smallholder suppliers.

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

25148.7 - The company discloses 25,148.66 ha of land for other uses but it is unclear if any of this land could be planted in the future.

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

109084 - Figure as of 2019.

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)?

13 - The company has 13 Forest management units.

22. Maps of forest management units (FMUs)?

The company only provides names of farms and a static map.

23. Forest management plans available for all FMUs?

Forest management plan 2020.

24. Monitoring of forest management plan implementation available?

The company reports multiple monitoring and management activities in its Forest Management Plan 2020. However, the information is not externally verified.

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?

FSC report the locations of suppliers to municipality level, however geo-referenced maps are not available. The data is undated and therefore no points have been awarded.

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 reports it has a pulp mill in Três Lagoas and also mentioned another mill (Vanguard 2.0 project) this new mill is being built next to the current bleached eucalyptus pulp mill.

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

The company reports names and locations of company owned pulp and paper mills.

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?

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 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.

39. Percentage of supply traceable to country of harvest?

40. Procedures to trace raw materials to FMU level?

Report procedures to trace raw material to the FMU level.

41. Percentage of supply traceable to FMU level?

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.

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?

96% - 95.8% of the company's area is certified under FSC & PEFC 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?

46. Percentage area (ha) FSC FM certified?

96% - The company's 95.8% area is certified under FSC & PEFC Certification.

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 provides a commitment to source wood fiber that meets FSC Controlled wood.

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

351,433.58ha (95.8% of total landbank) is certified by CERFLOR (PEFC - Brazil) but this is the same area that is certified by FSC FM so points cannot be awarded.

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). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership.

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

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

54. Evidence of monitoring deforestation?

The company reports it has a 3D farm monitoring system in which drones are monitoring daily to identify 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).

55. Evidence of monitoring deforestation in supplier operations?

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

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

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

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

60. Implementing a landscape or jurisdictional level approach?

Points for external verification have been awarded on the basis of the company's 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.

61. Commitment to biodiversity conservation?

The company reports a commitment to biodiversity conservation.

62. Commitment to biodiversity conservation applies to all suppliers?

The company has published this commitment.

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

[Externally verified] The company has disclosed species of conservation concern in its operations referring to the 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?

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 makes this commitment.

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

The company has published this commitment.

67. Commitment to protect forest areas from illegal activities?

The company has an explicit commitment to protect forest areas from illegal activities.

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

The company has an explicit commitment to protect forest areas from illegal activities that applies to all its suppliers.

69. Evidence of protecting forest areas from illegal activities?

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 in its forest management plan.

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

HCV assessment and monitoring plans are available in the forest management plan.

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

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

78. High Carbon Stock (HCS) assessments available?

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

The company makes this commitment.

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

The company has published a commitment to conduct social and environmental impact assessment that applies to all its suppliers.

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

The company has provided a summary of social and environmental impact assessment in its Forest management plan. However, the information is not externally verified.

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?

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?

The company has published a commitment to zero burning.

94. Commitment to zero burning applies to all suppliers?

95. Evidence of fire monitoring and management?

351,433.58ha (95.8% of total landbank) is certified by CERFLOR (PEFC - Brazil) but this is the same area that is certified by FSC FM so additional points cannot be awarded. 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 company reports 0.12 T CO2 eq/ADT GHG emission intensity in 2019. Data does not cover all forestry operations.

100. GHG emissions from land use change?

101. Progress towards commitment to reduce GHG emissions intensity?

The company reports progress towards reducing GHG intensity over a period of three years:0.16 (2017) 0.14 (2018) 0.12(2019).

102. Methodology used to calculate GHG emissions?

Brazilian GHG Protocol.

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

104. Water use intensity?

24.96 - The company reports 24.96 m³/tsa water intensity in 2019.

105. Progress towards commitment on water use intensity?

Progress towards water consumption intensity- 26,362.34(2016) 25,711.60(2017) 25,349.42 (2018) and 24.96 (2019).

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

107. 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. Also, the data is between two and five years old.

108. Treatment of pulp and paper mill effluent?

The company states that the water used in the production of pulp is treated at an on-site wastewater treatment plant.

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 provides limited information about the protection of natural waterways.

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?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN) and through the PEFC International Standard (PEFC ST 1003:2010). Partial points have therefore been awarded on the basis of the company's FSC and PEFC certified landbank of 96%.

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?

The company is 96% FSC FM and PEFC FM certified. As the percentages fro each certification are unclear, partial points have bee awarded. The company makes this commitment through the PEFC International Standard (PEFC ST 1003:2010). As the Standard's requirements do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's PEFC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years.).

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?

Reports list of chemical usage.

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?

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.

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 is FSC and PEFC Certified.

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 is committed to provide essential community services and facilities.

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?

The company is committed to eliminate gender-related discrimination with regard to employment.

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

The company is committed to eliminate gender-related discrimination with regard to employment that applies to all suppliers.

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

149. Percentage or number of temporary employees?

150. Percentage or number of women employees?

236 - The company reports it has 236 women employees across all its operations.

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?

154. Reporting of salary by gender?

155. Commitment to address occupational health and safety?

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

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

The company has provided the commitment to address occupational health and safety that applies to both the company as its suppliers but no reference to the ILO Code of Practice on Safety and Health in Forestry Work given.

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?

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 has provided multiple programmes to support small farmers such as providing technical training and PAIS Project to practice organic agriculture.

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

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

The company state that all its suppliers undergo an onboarding due diligence process in which they are requested to produce documents and statements of conformity under our Code of Conduct. However, it is unclear whether it covers all three key elements of due diligence.

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

409 - The company reports it has 409 suppliers and all the suppliers were assessed on compliance with the company's policy in 2019. However, the information is not externally verified.

165. Suspension or exclusion criteria for suppliers?

The company reports that all the suppliers contracted in 2018 were screened to verify the observation of human rights, labor rights, and compliance with environmental legislation and the company does not provide any information found regarding timeframes for action.

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 has an explicit commitment to ethical conduct and the prohibition of corruption.

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

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

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

The company has provided anti-corruption training to the employees and also started multiple initiatives for the prohibition of corruption (e.g. Annual Compliance Campaign, Code of Conduct Comic Book & Compliance Toolbox Talks.).

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

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

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

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

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

174. Whistleblowing procedure?

The company has an external Ombudsman channel named Ethics Hotlines. The whistleblowing process is outlined.

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

The company has its own grievance system open to all stakeholders.

176. Details of complaints and grievances disclosed?

The company only discloses the number of grievances about human rights impacts filed through grievance mechanisms, Number of grievances addressed, Number of grievances resolved & Number of complaints filed prior to the reporting period that was resolved during the reporting period.