Klabin SA

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

The company has a commitment to responsible forest management, combined with the various actions for environmental preservation and social responsibility for all its operations.

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

The company has a commitment to responsible forest management, combined with the various actions for environmental preservation and social responsibility, which applies to all its suppliers.

3. High-level position of responsibility for sustainability?

The company has a sustainability committee but the high-level responsibility of sustainability excluding the board is unclear.

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

Reported in 2019.

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

124 - The company reported 124 women in its management and coordination.

6. Percentage or number of women board members?

6 - In the Board of Directors 1/12 members are women. In the Administrative Council 6/33 are women. Data as of 2019.

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 & UNGC.

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

The company collaborates with stakeholders in projects assisting FSC certification for small producers and planning sustainable properties.

9. Sustainability report published within last two years?

The company has published its last sustainability report in 2019.

10. Reports through standardised reporting systems?

GRI Standards, CDP (Forest, Water Security, and Climate Change reports 2020).

11. Climate risks assessment available?

[Externally verified] The company made a commitment to the United Nations (UN) and civil society to establish targets and goals to reduce the impacts of climate change by 2050. Also, CDP Climate Change Questionnaire 2019 is publically available.

12. Natural capital assessment available?

13. Lists countries and operations?

The company has 24 industrial units out of which 23 are in Brazil and one industrial unit in Argentina.

14. Lists countries sourcing from?

The company states that about 7000 active suppliers are distributed throughout Brazil, are part of Klabin's supply chain.

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

16. Total area of forest plantation (ha)?

270,000 - The company reports the total planted area as 270,000 ha, unclear if this includes outgrower areas.

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

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

17.139 - The company reports that in 2018, 17.139 ha area is unplanted (excluding logistical areas). Data is over two years old.

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

240,000 - The company reports that it has 240,000 ha (43%) area set aside for conservation.

20. Area of Intact Forest Landscape (ha)?

21. Number of Forest Management Units (FMUs)?

3 - The company has three forest management units in Paraná, Santa Catarina, and São Paulo.

22. Maps of forest management units (FMUs)?

The company only publishes static maps of its FMUs in the Forest Management Plans.

23. Forest management plans available for all FMUs?

The company has published Forest Management Plan for all three FMUs.

24. Monitoring of forest management plan implementation available?

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.

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?

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?

24 - The company states that it has 24 industrial plants (23 in Brazil and one in Argentina). However, it is unclear if all industrial units are pulp and paper mills.

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

The company has provided the map that shows the addresses of industrial units, but it is not clear if all are 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?

The company is outsourcing 27.6% of its wood from smallholders and the rest 70% from its own operation. Data is over two years old.

35. Number of third party supplying mills?

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

This indicator is disabled as the company reports that it doesn't source from supplying mills.

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

The company has FSC CoC certification and it commits to following Controlled Wood criteria and processes for non-certified raw materials.

39. Percentage of supply traceable to country of harvest?

100 - The company states that all wood suppliers are traceable and audited based on Controlled Wood and Chain of Custody criteria including field visits.

40. Procedures to trace raw materials to FMU level?

The company has FSC CoC certification and it commits to following Controlled Wood criteria and processes for non-certified raw materials. The company also carries out audits for all of its suppliers on a quarterly basis.

41. Percentage of supply traceable to FMU level?

The company states that all wood suppliers are traceable and audited based on Controlled Wood and Chain of Custody criteria including field visits.

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

The company is 100% FSC certified, already met the target.

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

100% - The company is 100% FSC certified, already met the target.

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

The Company have commited that 100% of their timber supply should be FSC certified by 2023.

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

26.9% - The company's Parana concession's supply is 47.5 % FSC certified and its Santa Catarina concession's supply 3.6% FSC certified.

46. Percentage area (ha) FSC FM certified?

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

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

100% FSC certification already met.

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

26.9% - The company's Parana concession's supply was 47.5 % FSC certified and its Santa Catarina concession supply 3.6% FSC certified.

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

The company has provided the commitment to source only wood/ wood fiber that meets FSC CW and COC certified.

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

This indicator is disabled as the company is either 100% FSC FM certified or is >75% certified and has a commitment to achieve 100% within 5 years.

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?

[Externally verified] The company reports it uses satellites, drones, tools such as "Lidar" data for a topographic survey to monitor deforestation. Also, this information is verified by Conecta Consultores.

55. Evidence of monitoring deforestation in supplier operations?

[Externally verified] The company reports it has satellite imagery and a monitoring system to ensure that the company and its suppliers are in line with the Brazilian Forest Code. The extent of area monitored and the timeframe for monitoring is not available.

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

0 - As per the CDP report, the company states that there was no deforestation in its estates in 2018. However, the data provided is between two and five years old.

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

0 (0%) - The company states that no evidence of deforestation was found in the activities of wood suppliers in 2018. However, the data is between two and five years old.

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

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

60. Implementing a landscape or jurisdictional level approach?

[Externally verified] The company is committed to sustainable development and mosaic planting. This helps to protect natural resources, improves the production potential of forests, and helps preserve biodiversity through ecological corridors.

61. Commitment to biodiversity conservation?

The company is committed to conserving biodiversity. Also, makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

62. Commitment to biodiversity conservation applies to all suppliers?

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

[Externally verified] The company has identified the species of conservation through the IUCN Red list system of classification. 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.

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

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

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

The company has provided the commitment to no hunting in its Forest management plans.

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

67. Commitment to protect forest areas from illegal activities?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

68. Commitment to protect forest areas from illegal activities applies to all 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). Full points have therefore been awarded on the basis of the company's FSC certification/FSC membership.

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 (AAVC) assessment summaries are available within the company's forest management plans. Evidence is self-reported.

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

HCV (AAVC) management and monitoring summaries are available in the company's forest management plans. Evidence is self-reported.

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 through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

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

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

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

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

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

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

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

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

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). However, specific provisions are not set out for peatland operations. Half points have therefore been awarded for this indicator 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).

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?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). 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).

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?

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

93. Commitment to zero burning?

The company has provided the commitment to zero burning.

94. Commitment to zero burning applies to all suppliers?

95. Evidence of fire monitoring and management?

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?

63 - The company only reports a total number of fires in 2/3 FMUs.

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

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

The company has a target to reduce GHG intensity to 185 kg CO2/t product from 2020 to 2022 (Goal not achieved yet).

99. GHG emissions intensity?

185.33 kg CO2 / t product (Scope 1+2+3). Figure as of 2019.

100. GHG emissions from land use change?

101. Progress towards commitment to reduce GHG emissions intensity?

The company has reported intensity of greenhouse gas emissions in tons per CO 2 equivalent 1 (scope 1 + 2 + 3) - 238.68 (2016) 235.17(2017) 218.93 (2018) 232.49(2019).

102. Methodology used to calculate GHG emissions?

Brazilian GHG Protocol.

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

The company sets a target to reduce water consumption by 5% between 2020-2022, however, the target is not based on water use intensity.

104. Water use intensity?

17,020.5 - The company reports total water consumption in 2019 was 17,020.52 Ml. Water use intensity is not disclosed.

105. Progress towards commitment on water use intensity?

[Externally verified] Total water consumption, in Megaliters (Ml)- 18,489.32 (2016) 12,065.25 (2017) 18,446.37 (2018) 17,020.52 (2019).

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

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

[Externally verified] The company has reported an increase in the discharge of effluents by 2% due to the inclusion of the Jundiaí Distrito Industrial and Jundiaí Tijuco Preto Units. This information is externally verified by Conecta Consultores.

108. Treatment of pulp and paper mill effluent?

[Externally verified] The company has explicitly mentioned the treatment of wastewater from pulp and paper mills. This information is externally verified by Conecta Consultores.

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 makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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.

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

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

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). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

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 makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

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?

The company only provides chemical usage per ha in its Parana and Angatuba-SP concessions, but this does not reflect the entirety of its concessions.

121. Implementation of commitment to reduce chemical usage?

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

122. Integrated Pest Management (IPM) approach?

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

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

[Externally verified] The company has a waste management system in place to avoid negative impacts. The information is externally verified by Conecta Consultores.

124. Commitment to human rights?

The company commits to the Universal Declaration of Human Rights. Also, 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's commitment to the Universal Declaration of Human Rights applies to all the suppliers. Also 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 ?

[Externally verified] The company reports that 33.33% of operations were subject to human rights impact assessments in 2019, not detail on the results are available. The information is externally verified by the Conecta Consultores.

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

The company's commitment to respect indigenous and local communities' rights is in place. Also, 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's commitment to respect indigenous and local communities' rights applies to all the suppliers and also, 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 Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

130. Commitment to legal and customary land rights applies to all suppliers?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). 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).

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

The company has a commitment that FPIC is respected across all operations.

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?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

[Externally verified] The company has reported multiple evidence of supporting women across all operations.

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?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

139. Commitment to provide essential community services and facilities ?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). Full points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

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 makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank (either 100% or >75% and a further commitment to be 100% certified within 5 years).

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

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

145. Progress on commitment to respect all workers' rights?

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.

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

The company has an explicit commitment to no 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 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?

0 (0%) - The company reports that in 2019, there were no employees on a temporary employment basis.

150. Percentage or number of women employees?

1,907 - The company reports it has 1907 women employees across all operations.

151. Commitment to pay at least minimum wage?

The company is committed to pay at least minimum wage in accordance with the National minimum and regional minimum wage.

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

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

[Externally verified] 1.02 - The company reports that in 2019, the lowest salary paid by the company was 1.02 times higher than the national minimum wage.

154. Reporting of salary by gender?

0.94 - The company has provided the Ratio of the basic salary and remuneration of women to men for each employee category.

155. Commitment to address occupational health and safety?

The company makes this commitment through the FSC Principles and Criteria (FSC-POL-01-004 V2-0 EN). As the P&Cs do not fully meet the SPOTT indicator criteria partial points have therefore been awarded on the basis of the company's FSC certified landbank 406093.7 ha (100% of the total operational area).

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

The company only has a commitment to address health and safety for its suppliers which does not reference ILO Code of Practice on Safety and Health in Forestry work.

157. Provision of personal protective equipment and related training?

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.

158. Time lost due to work-based injuries?

6.3 - The company reports the Rate of recordable work-related injury rate in 2019 as 6.30. Unit of measurement is not disclosed.

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

0 - The company has reported no work-based fatalities in 2019.

160. Commitment to support smallholders?

The company has provided the commitment to support smallholders.

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

[Externally verified] The company involve itself in many partnerships to support local smallholders, such as Mata Legais and plant with Klabin to increase family income and awareness on environmental issues. This information has been verified by Conecta Consultores.

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

[Externally verified] 383 - The company reports that in 2018, the Small Rural Producers Forest Certification Program has allowed 383 local producers to become certified.

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

The company had a criticality matrix to evaluate the critical suppliers contracted in the industrial area and the risks they pose to the company, both financially and regarding sustainability.

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

[Externally verified] 472 - The company reports 472 suppliers were selected to participate in the assessment, which considers questions grouped into four topics: Environment, Labor and Human Rights, Ethics, and Sustainable Procurement. This assessment is verified by Conecta Consultores.

165. Suspension or exclusion criteria for suppliers?

The company has a policy for the supply of goods and services which states that any violation of the provisions of its social and environmental responsibilities may be considered as sufficient reason for the immediate suspension of contractual supply.

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?

The company has multiple sources of information showing it visits suppliers to evaluate compliance, but no figures could be found reporting the proportion of direct and indirect supply that is compliant with a sourcing policy.

168. Commitment to ethical conduct and prohibition of corruption?

The company has a commitment to ethical conduct and the prohibition of corruption.

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

The company is committed to ethical conduct and the prohibition of corruption which applies to all its suppliers.

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

[Externally verified] The company reports that it has conducted training for its employees to mitigate briber and corruption. This information is verified by the Conecta Consultores.

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?

The company discloses its management approach to tax through its Tax Guidance Policy.

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?

Whistleblowing and grievances are reported through an ombudsman channel, with anonymity guaranteed.

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

The company has provided an independent Ombudsman channel on its website.

176. Details of complaints and grievances disclosed?

The company discloses the number of complaints received in 2019 and their respective status. i.e., the number of complaints resolved, forwarded, and pending. However, the complainant category, dates, and action taken to resolve the complaints are not disclosed.