Interholco

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

The company has a responsible forest management and procurement policy that covers multiple dimensions of sustainability across the company's operations covering both social and environmental issues.

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

The company's responsible forest management and procurement policy applies to all its suppliers.

3. High-level position of responsibility for sustainability?

The company has a Head of Sustainability.

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

This indicator is disabled as the company reports that it is either privately owned or does not have a Board of Directors.

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

0 - The company reports no women in the senior management team in 2021.

6. Percentage or number of women board members?

This indicator is disabled as the company reports that it is either privately owned or does not have a Board of Directors.

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, STTC, CBFP, ATIBT, UNGC and multiple others.

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

In 2022, the company equipped schools located within the company's concession with a sanitation system to provide clean water. In 2021, the company began working with the Republic of Congo's Ministry of Forest Economy, WCS, and CIRAD to increase the participation of communities in sustainable forest management. In 2018, the company participated in a working group addressing forest fires in Marantaceae forests, the High Conservation Values Regional Working Group for the Congo Basin aiming to protect Intact Forest Landscapes, and hosted an academic research group.

9. Sustainability report published within last two years?

The last sustainability report was published in 2022.

10. Reports through standardised reporting systems?

The company's last sustainability report was published in 2022 according to GRI Core standards.

11. Climate risks assessment available?

The company has published a climate risk assessment, however it is not externally verified.

12. Natural capital assessment available?

The company has published a natural capital assessment based on the Natural Capital Protocol, including a case study of this assessment which is available on the Natural Capitals Coalition website.

13. Lists countries and operations?

Republic of Congo (forest concessions and sawmills).

14. Lists countries sourcing from?

As of 2022, the company's main suppliers are in Cameroon, C?te d'Ivoire, Gabon, Ghana, Central African Republic, Democratic Republic of Congo, Republic of Congo, Canada and the United States.

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

1159000 - The total area managed for forestry is 1,159,000 ha.

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

801716 - Figure as of 2021.

17. Total area of forest plantation (ha)?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

18. 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.

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

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

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

308000 - Figure as of 2021.

21. Area of Intact Forest Landscape (ha)?

332492 - The company reported its area of intact forest landscape in 2022.

22. Number of Forest Management Units (FMUs)?

1 - The company has one forest management unit.

23. Maps of forest management units (FMUs)?

The map of the company's Ngombe concession, managed by IFO, is hosted on WRI Global Forest Watch, the Forest Atlas, and is also published in the company's FSC certification reports.

24. Forest management plans available for all FMUs?

The company has published an FMP for its single FMU.

25. Monitoring of forest management plan implementation available?

[Externally verified] The company has a monitoring report and FSC audit reports contain some monitoring information. FSC audit reports are externally verified.

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

[Externally verified] The company has provided 2 out of the 2 total valid legal documents required by Open Timber Portal on use right. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

[Externally verified] The company has provided 5 out of the 5 total valid legal documents required by Open Timber Portal on forest management. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

[Externally verified] The company has provided 4 out of the 4 total valid legal documents required by Open Timber Portal on timber harvesting. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

The company reports a list of 'most important suppliers' with links to publicly available maps. As the list does not include all suppliers full points cannot be awarded.

30. Number of company owned sawmills?

3 - The company states that it has three sawmills.

31. Names and locations of company owned sawmills?

The company has a sawmill, lamination and planing mill, and a heavy timber mill on one site.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

The company reports that all the wood processed by the sawmills of its subsidiary IFO (Industrie foresti?re de Ouesso) comes from the forest managed by IFO. The company also sources wood from suppliers, but it is not processed either by IFO or at IFO.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

36. Number of third party supplying mills?

21 - Figure as of 2021.

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

The company provides the names, addresses, static maps, and GoogleMaps locations for 6/21 supplying sawmills.

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

The company reports it sourced 99,200 m3 of wood in 2021, 13% was from third party suppliers' own forest or forest in partnership agreement, and 3.1% was from traders or sawmills, from other forests, including EU or USA supply.

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

The company reports it has a legality verification system for traceability of its wood products, and publishes the details of the process.

40. Percentage of supply traceable to country of harvest?

100 - The company states that 88% of sourced wood is FSC FM certified, 5% PEFC controlled wood and PEFC certified, 6% 2nd party verified via a due diligence process, and 1.3% from low risk regions including the EU.

41. Procedures to trace raw materials to FMU level?

The company publishes the process through which it traces raw material to the forest of harvest.

42. Percentage of supply traceable to FMU level?

In 2021, 88% of the company's supply is FSC FM certified, 5% is third-party verified (PEFC CS & CoC, FSC CW), 6% is verified by the company's own process which traces wood to the forest of harvest. The remaining 1.3% reported by the company comes from the EU and other low risk regions, therefore it is unclear if supply can be traced back to FMU level.

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

The company's single concession is 100% FSC FM certified.

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

[Externally verified] 100% - 100% of the company operations are FSC-FM certified.

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

In 2019, the company published a commitment to procure only 3rd party legality verified or certified timber within 10 years.

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

93% - 88% of company supply is FSC FM certified, and an additional 5% is verified for legality by a third-party (either FSC Controlled Wood or PEFC certified).

47. Percentage area (ha) FSC FM certified?

100% - The company is 100% FSC FM certified.

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

The company already reached 100% FSC-FM certification of its FMU.

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

88% - The company reports that 88% of its wood supply is FSC FM certified.

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

The company reports its commitment in its responsible forest management and procurement policy.

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

52. Commitment to zero conversion of natural ecosystems?

The company commits to zero conversion of natural ecosystems.

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

The company commits all suppliers to zero conversion of all natural ecosystems.

54. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

55. Commitment to zero deforestation applies to all suppliers?

The company commits all suppliers to zero deforestation.

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?

The company defines deforestation as the conversion or clearing of forests to plantations or other non-forest uses from January 2020 onwards.

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

[Externally verified] The company monitors deforestation via satellite data on Global Forest Watch (GFW) and via foot patrols. The data is externally verified.

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

The company reports that its suppliers are subject to 2nd and 3rd party audits and that no supplier was involved in deforestation as of 2021. Deforestation is monitored annually, via Global Forest Watch, and monitoring covers 4 million ha of forest (90% of supply).

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

0 - In 2021, the company reported 0 ha of deforestation has occurred in its operational area since 2014, and therefore since its cut-off date of January 2020.

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

0 (0%) - The company reports that none of its suppliers have been involved in deforestation since the cut-off date of January 2020.

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

The company commits to restore any area of deforestation/conversion in its own operations since January 2020.

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

The company requires its suppliers to restore any area of deforestation/conversion from January 2020 onwards.

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company reports signing an MoU with the African Parks Foundation in 2020 allowing cooperation on activities pertaining to wildlife management and is part of the Forest Forward multi-stakeholder platform by WWF which aims to improve the management of 150 million hectares of forest by 2030. Evidence is externally verified via evidence on project partner websites.

65. Biodiversity policy?

The company has published a biodiversity policy which covers multiple dimensions of biodiversity protection, extends beyond HCV/HCS/set-asides and details time-bound targets on protecting biodiversity. Targets include maintaining a zero deforestation rate, and maintaining elephant and gorilla populations.

66. Biodiversity policy applies to all suppliers?

The company has published a biodiversity policy which applies to all suppliers, covers multiple dimensions of biodiversity protection and extends beyond HCV/HCS/set-asides.

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

[Externally verified] The company has identified species of conservation concern using the IUCN red list, including the critically endangered western lowland gorilla in its concession. Information is externally verified via an academic paper and a collaborative report with NGOs.

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 commits to only allow sustainable hunting of species by local communities for subsistence purposes in its operations.

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

The company commits all suppliers to only allow sustainable hunting of species by local communities for subsistence purposes in their operations.

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?

The company commits suppliers to protect the natural ecosystems and plantations under their management from illegal activities.

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?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

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

This indicator is disabled as the company reports that it only sources from natural forests.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

The company commits all suppliers to conduct HCV assessments.

78. High Conservation Value (HCV) assessments available?

[Externally verified] The company has published an HCV assessment and a summary in its forest management plan which is externally verified by Forest Resources Management.

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

[Externally verified] The company has published an HCV assessment which includes management and monitoring plans, this document is externally verified by Forest Resources Management. Evidence of monitoring can also be found in FSC surveillance audits and reports published by the company.

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

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

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

This indicator is disabled as the company reports that it only sources from natural forests.

82. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

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

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

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?

The company commits all suppliers to conduct social and environmental impact assessments.

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

[Externally verified] The company provides an SEIA with associated management and monitoring plans. The report is externally verified by Impact Congo Negoce.

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

[Externally verified] The company has provided 3 out of the 3 total valid legal documents required by Open Timber Portal on impact assessments. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

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

This indicator is disabled as the company reports that it only sources from natural forests.

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

280000 - As of 2021.

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

This indicator is disabled as the company reports all peat is in conservation set-asides.

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

All peatland is protected and not harvested by the company. 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.).

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

The company commits suppliers to BMPs for soils and peat.

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

The company reports that all peatland is protected and not harvested. 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.

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?

The company commits all suppliers to Reduced Impact Logging (RIL) and specifically mentions minimising the impact of logging roads along with other RIL practices.

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?

This indicator is disabled as the company reports that it only produces wood/wood fibre from natural forests.

99. Commitment to zero burning applies to all suppliers?

This indicator is disabled as the company reports that it only sources from natural forests.

100. Evidence of fire monitoring and management?

The company reports that it has two teams of 30 fire rescuers and satellite phones to issue fire alerts from anywhere in the company's operational area. The company also reports that it monitors fires through Global Forest Watch, conducts fire management training, and has detailed fire management procedures. This information is externally verified.

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

0 - No fires were recorded in 2021.

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

0 - No fires were reported in supplier concessions in 2021.

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

The company has a commitment to reduce in-forest emissions of CO2 per m3 of wood produced by 10% by 2025. Additionally, a commitment to reduce CO2 per m3 of wood produced by 5% by 2025 is reported for non-biogenic emissions during forest production, wood processing and national and international transport. This applies to scope 1, 2, and 3 emissions.

104. GHG emissions intensity?

The company reports 0.83 tCO2/m3 for 2021. The figure includes scope 1, 2, and 3 emissions.

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

This indicator is disabled as the company reports that it only produces wood/wood fibre from plantations.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

107. Progress towards commitment to reduce GHG emissions intensity?

The company reports a reduction in emissions intensity (CO2 per m3 lumber) from 0.88 in 2020 to 0.83 in 2021. However this data is not externally verified.

108. Methodology used to calculate GHG emissions?

Emission factors from UK DEFRA and US EPA; the IPCC, 2006 Guidelines for National GHG Inventories; World Resources Institute (2015) GHG Protocol tool for mobile combustion.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

110. Water use intensity?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

111. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

114. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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

The company mentions wastewater treatment and checking pollution levels before discharging water, but no examples are given.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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 (either 100% or >75% and a further commitment to be 100% certified within 5 years). The company also publishes this commitment independently.

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?

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

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

This indicator is disabled as the company reports that it does not own pulp or paper mills.

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?

The company's commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all its 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?

The company commits all suppliers to not use Stockholm and Rotterdam Convention chemicals.

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

In 2020, no pesticides or fertilisers were used in its natural forest management.

127. Implementation of commitment to minimise inorganic fertiliser usage?

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

128. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] The company has a waste management system in place to avoid negative impacts.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

131. Commitment to human rights applies to all suppliers?

The company commits all suppliers to the Universal Declaration of Human Rights.

132. Progress on human rights commitment ?

[Externally verified] The company reports that it provides training on human rights to its employees and eco-guards. Evidence of a training workshop in 2020 has been externally verified by an NGO.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

The company commits all suppliers to the UN Declaration on the Rights of Indigenous Peoples.

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

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

The company commits all suppliers to respect legal and customary land tenure rights.

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

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

The company commits all suppliers to FPIC.

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

The company reports the details of its free, prior and informed consent (FPIC) process, and refers to FAO's guidelines in its FAQ document.

140. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] The company reports meetings with local and indigenous communities, permanent staff members who are responsible for community dialogue, and training to prevent conflicts. Evidence is externally verified from contributions to an article by a government official, and comments from employees in an article published on the FSC website.

141. Details of process for addressing land conflicts available?

The company has published a process.

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

The company declares supporting women employees by giving equal training opportunities, offering maternity support and providing mechanisms to report harassment. Indigenous women are included by the company's social team that ensures women are involved in local consultations and FPIC processes.

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

[Externally verified] The company has provided 4 out of the 4 total valid legal documents required by Open Timber Portal on population rights. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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 has published this commitment.

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

[Externally verified] The company has provided 7 out of the 7 total valid legal documents required by Open Timber Portal on labour regulations. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V2-0). Full points have therefore been awarded on the basis of the company's FSC certification.

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

The company has published this commitment.

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 has published this commitment.

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

The company's commitment to eliminate gender-related discrimination with regards to employment applies to all its suppliers.

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

[Externally verified] The company has introduced a notification/complaints system within its HR department to specifically identify and address instances of gender-related discrimination and introduced female only workstations. The company also runs women only meetings.

155. Percentage or number of temporary employees?

6 - The company reports 6 temporary employees in 2021.

156. Percentage or number of women employees?

50 (5.2%) - In 2021, 50 of 960 employees were women.

157. Commitment to pay a living wage?

The company has published this commitment.

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

The company commits suppliers to pay full time employees the minimum wage.

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. The company also reports the living wage paid to employees against the minimum wage per country, however figures are not externally verified.

160. Reporting of salary by gender?

The company reports salaries paid by gender for entry level employees in the Republic of Congo. Full points could not be awarded because the ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation, was not reported.

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 has published this commitment.

163. Provision of personal protective equipment and related training?

The company provides PPE and training to employees. Information has been externally verified via a LegalSource audit report.

164. Time lost due to work-based injuries?

5.8 - The company reports the incident rate (per 100 workers) of injuries with temporary leave of more than 4 days for 2021.

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

1 - Figure as of 2021.

166. Commitment to support smallholders?

This indicator is disabled as the company reports that it does not source wood/wood fibre from smallholders.

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

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

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

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

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

The company has a due diligence system that includes a form to gather information on many aspects of the supplier and products, a method for assessing legality, traceability and sustainability risks, ensuring compliance with company policies, and identifying mitigation measures.

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

100% - The company reports 100% compliance on its Responsible Procurement Policy has been achieved via a certified due diligence process including field audit of high risk suppliers. However, the figure that all suppliers are in compliance has not been externally verified.

171. Suspension or exclusion criteria for suppliers?

The company's risk analysis/due diligence system includes the criteria which may lead to the exclusion of the suppliers. The company reports that major deviations must be resolved within three months and minor deviations are to be resolved within a longer period, often one year, after which contracts are terminated.

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

The company's entire supply was compliant as of 2021.

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

All supply was compliant in 2021.

174. Commitment to ethical conduct and prohibition of corruption?

The company has published this commitment.

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

The company's commitment to both ethical/fair conduct and prohibition of corruption applies to all its suppliers.

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

The company reports it trained 960 employees in anti-bribery and corruption in 2021. Information is not externally verified.

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

[Externally verified] The company has provided 4 out of the 4 total valid legal documents required by Open Timber Portal on legal registration. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

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

The company has published a tax policy.

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

[Externally verified] The company has provided 2 out of the 2 total valid legal documents required by Open Timber Portal on taxes, fees, and royalties. Please note: Company scores on Open Timber Portal are updated daily. Visit the OTP website to review the company's current performance by clicking on the source link.

180. Whistleblowing procedure?

The company reports that all employees can report unethical conduct securely and confidentially through its grievance mechanism, which is described in detail.

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

The company has a grievance mechanism open to all stakeholders with a clear description of steps taken.

182. Details of complaints and grievances disclosed?

Thee company has disclosed comprehensive detail on grievances.